News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Due Diligence Enforcement Actions

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

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

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 12th - 13th, Polanco, CDMX, Mexico

Connect with the leading Anti-Corruption experts and discuss the latest compliance strategies at ACI’s Mexico Summit on Anti-Corruption & Compliance Programs. As Mexico’s longest running, premier anti-corruption and...more

Bracewell LLP

Guiding Your Company Through Trump’s New Latin America Enforcement Policy

Bracewell LLP on

Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...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

American Conference Institute (ACI)

[Event] The Brazil Summit on Anti-Corruption, Integrity & ESG - May 22nd - 23rd, São Paulo, Brazil

Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Paul Hastings LLP

Safe Harbor in the Coming Enforcement Storm? DOJ Announces New M&A Policy to Encourage Compliance

Paul Hastings LLP on

On October 4, 2023, Deputy Attorney General Lisa Monaco (the “DAG”) announced a new Mergers & Acquisitions (“M&A”) Safe Harbor Policy issued by the Department of Justice (“DOJ”) as part of her comments detailing increased...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

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

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

American Conference Institute (ACI)

[Event] 11th Summit on Anti-Corruption Brazil - May 25th - 26th, São Paulo - State of São Paulo, Brazil

Brazil’s Anti-Corruption and Compliance Community Will Gather for Large, 1:1 and Smaller-Group Discussion! As the longest-standing anti-corruption and compliance gathering in Brazil, Summit on Anti-Corruption Brazil is...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

The Volkov Law Group

Credit Suisse’s Global Bribery and Fraud Scheme (Part II of II)

The Volkov Law Group on

The Credit Suisse case highlights the significant impact that global corruption and fraud can have on developing economies.  Mozambique’s economy suffered serious harm from the scheme, which started to unravel when the IMF...more

The Volkov Law Group

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on

The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Global Compliance Updates - November 2nd - 3rd, 5:55 pm - 8:15 pm GST

Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Continues Targeting of Corruption through AML Laws and Alternate Statutes – Lessons for Compliance and Due Diligence

As the Biden Administration commits to crack down on corruption, recent enforcement actions show the DOJ continues a longstanding trend of relying on AML laws and other alternate statutes to prosecute corruption cases, with...more

The Volkov Law Group

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

The Volkov Law Group on

We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues.  It does not take a rocket scientist to...more

The Volkov Law Group

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

The Volkov Law Group on

FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more

Society of Corporate Compliance and Ethics...

[Virtual Event] 2021 Middle East and Africa Regional Compliance & Ethics Conference - February 11th, 8:55 am - 2:00 pm GST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Society of Corporate Compliance and Ethics...

Compliance Perspectives: The Latest from the Fraud Section at the US Department of Justice

In the latest episode of the Compliance Perspectives podcast we are joined by Daniel Kahn, the Acting Chief of the Fraud Section at the Department of Justice. We begin the conversation with a discussion of the latest...more

McDermott Will & Emery

[Webinar] 2020 Latin American Compliance Conference - November 19th, 12:15 pm - 2:00 pm EST

McDermott Will & Emery on

Join us virtually for a Latin American Compliance Conference where senior government officials, industry experts and key US and Latin American lawyers discuss anti-corruption and Foreign Corrupt Practices Act (FCPA)...more

Perkins Coie

Rare DOJ Opinion Offers Anti-Bribery Lessons for Transactions Involving Foreign Government-Owned Assets

Perkins Coie on

The U.S. Department of Justice (DOJ) has issued an opinion letter (catalogued as FCPA Opinion No. 20-01) stating that it does not intend to take enforcement action under the Foreign Corrupt Practices Act (FCPA) against a...more

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