News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Due Diligence Bribery

Morgan Lewis

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Morgan Lewis on

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

Hogan Lovells

DOJ's pause on FCPA is a compliance shake up for businesses

Hogan Lovells on

This article was originally published by Bloomberg Law on April 10, 2025, and is republished here with permission. Read the original article here: DOJ’s Pause on FCPA Is a Compliance Shake-Up for Businesses – Bloomberg Law. ...more

Ankura

Internal Control Lessons Learned from Global Anti-Corruption Enforcement in 2024

Ankura on

2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more

Ankura

The Extended Network: Managing Third Parties' Bribery Risks

Ankura on

Approximately 90% of U.S. Foreign Corrupt Practices Act (FCPA) enforcement cases from its inception in 1978 have involved third-party intermediaries engaging in bribery schemes. The reduced level of control or oversight...more

American Conference Institute (ACI)

An FCPA Enforcement Pause Does Not Pause Anti-Corruption Compliance

U.S. Foreign Corrupt Practices Act (FCPA) enforcement activity may be at a temporary standstill, but that should not mean much for the day-to-day operations of global anti-corruption compliance programs. If the Department of...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - December 2nd - 5th, 8:00 am - 5:00 pm CT

Learn the key principles of compliance - no travel required! If you’re new to or have minimal experience in compliance management don’t miss this opportunity to build the foundational knowledge you need! SCCE’s four-day...more

Benesch

White Collar Quarterly Report - August 2024

Benesch on

In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - May 13th - 16th, 9:00 am - 3:00 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program in a convenient virtual format. The curriculum is ideal for those new to or with little...more

Thomas Fox - Compliance Evangelist

Levels of Due Diligence

Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

ArentFox Schiff

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

ArentFox Schiff on

On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - December 4th - 7th, 9:00 am - 3:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

American Conference Institute (ACI)

[Event] 9th Anti-Corruption and Corporate Social Responsibility Conference - October 9th - 10th, Puteaux, France

Hosted by C5 Group, the 9th Anti-Corruption Conference in Paris returns for another exciting year with curated programming that will shed light on important issues at the forefront....more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - October 16th - 19th, 11:55 am - 6:30 pm CET

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - September 18th - 21st, 9:00 am - 2:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

The Volkov Law Group

Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

The Volkov Law Group on

Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group,...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - May 15th - 18th, 8:55 am - 3:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

Guidepost Solutions LLC

Mergers + Acquisitions: 5 Tips For Navigating FCPA Risks

Among the risks inherent in a merger or an acquisition, few bring the financial and reputational consequences of the U.S. Foreign Corrupt Practices Act (“FCPA”). Background - The FCPA prohibits the offer, promise,...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - February 6th - 9th, 8:55 am - 3:30 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - October 31st - November 3rd, 8:55 am - 2:30 pm CDT

SCCE’s Compliance & Ethics Essentials Workshop provides a comprehensive introduction to the elements of a compliance program to enable attendees to be a more effective member of the compliance team. The workshop is ideal for...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - August 8th - 11th, 8:55 am - 3:30 pm CDT

SCCE’s Compliance & Ethics Essentials Workshop provides a comprehensive introduction to the elements of a compliance program to enable attendees to be a more effective member of the compliance team. The workshop is ideal for...more

Morgan Lewis

Due Diligence, Ethics, and Compliance Considerations for Dealmakers

Morgan Lewis on

In recent years, the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC) have further defined their anti-corruption due diligence and disclosure expectations of acquiring companies pre- and...more

The Volkov Law Group

Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III)

The Volkov Law Group on

Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - February 14th - 17th, 8:55 am - 2:30 pm CST

SCCE’s Compliance & Ethics Essentials Workshop provides a comprehensive introduction to the elements of a compliance program to enable attendees to be a more effective member of the compliance team. The workshop is ideal for...more

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