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Foreign Corrupt Practices Act (FCPA) Fraud Risk Management

Womble Bond Dickinson

The UK's Failure to Prevent Fraud Offense

Womble Bond Dickinson on

Effective September 1, 2025, the UK’s Failure to Prevent Fraud offense will go into effect as part of the UK’s Economic Crime and Corporate Transparency Act 2023 (the ECCTA). The law significantly expands corporate liability...more

Hinshaw & Culbertson - Consumer Financial...

An In-House Compliance Guide for Responding to President Trump's Executive Order on Foreign Corrupt Practices Act Enforcement

As has widely been published, on February 10, 2025, President Trump signed Executive Order (EO) 14209, which paused all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least...more

Bracewell LLP

Keeping an Eye on AI: DOJ Updates its Playbook for Corporate Compliance

Bracewell LLP on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more

Thomas Fox - Compliance Evangelist

Culture Week: Part 3- A Toxic Culture and the Fraud Triangle

We continue our exploration of corporate culture. Today, we consider the intersection of the Fraud Triangle and a toxic culture. The Fraud Triangle is well-known to most compliance practitioners. It is pressure, opportunity,...more

American Conference Institute (ACI)

[Event] 18th Annual Conference on Anti-Corruption - June 18th - 19th, London, United Kingdom

Hosted by the C5 Group, the 18th Annual Conference on Anti-Corruption London will bring together the brightest minds in anti-corruption and compliance to review the most pressing multi-jurisdictional enforcement updates...more

Guidepost Solutions LLC

Focus on Foreign Banks’ Sanctions Compliance Programs in the U.S. and Globally - Upgrading and Empowering Compliance to Help...

As the Russia – Ukraine war rages on, one outcome so far is clear: the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against...more

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

Foodman CPAs & Advisors

How Is Your Organization’s Performance With Respect To Fraud?

US Regulations including the Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley Act and Anti-Bribery legislation require that Management in a business have a zero tolerance for fraud and have an Audit Committee in place...more

The Volkov Law Group

Deutsche Bank Agrees to Pay $130 Million to Resolve FCPA and Fraud Cases (Part I of II)

The Volkov Law Group on

Deutsche Bank, the infamous German bank connected to President Trump, settled FCPA and fraud cases with the Justice Department and the SEC, and agreed to pay a total of $130 million....more

ArentFox Schiff

Deutsche Bank DPA Reflects Government’s Focus on Third-Party Risk Management and Data-Driven Compliance Programs

ArentFox Schiff on

On January 8, 2021, US authorities announced that they reached an agreement with Deutsche Bank Aktiengesellschaft (Deutsche Bank) to resolve the government’s investigation into violations of the Foreign Corrupt Practices Act...more

Foodman CPAs & Advisors

Trabajando juntos, los abogados y los contadores forenses pueden brindar soluciones óptimas

Foodman CPAs & Advisors on

Existe una propuesta de valor presentable a un cliente cuando un abogado trabaja en conjunto con un contador forense.  Los litigios a menudo implican la superposición de múltiples y complejos asuntos legales y contables....more

Foodman CPAs & Advisors

Working together, Attorneys and Forensic Accountants Can Bring About Optimal Solutions

Foodman CPAs & Advisors on

There is a value added for a client when an Attorney is working in tandem with a forensic accountant. Litigation often involves overlapping complex accounting and legal issues. Working together, Attorneys and Forensic...more

Foodman CPAs & Advisors

Should Business Owners rely on Whistleblowers or Forensic Accountants?

Foodman CPAs & Advisors on

According to a recent Foreign Corrupt Practices Act (FCPA) Blog entry (11/28/18), over 40% of internal frauds are discovered by whistleblowers and statistics show that 74% of whistleblowers are terminated. ...more

Thomas Fox - Compliance Evangelist

SCCE Compliance and Ethics Institute – Eugene Soltes and How Compliance Programs Works

The first full day of the SCCE 2017 Compliance and Ethics Institute (CEI) featured a talk by Eugene Soltes, an associate professor at Harvard Business School and author of “Why They Do It”. For this book Soltes spent over...more

Thomas Fox - Compliance Evangelist

The Fraud Triangle, Rationalizations and Compliance Programs

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Thomas Fox - Compliance Evangelist

Midnight Cruising with Steely Dan – Finding Patterns in Raked Leaves

Last Friday on September 1, I began a new installment of my year-long podcast series, where each month I focus on a different compliance topic. This month, I am focusing on innovation in compliance....more

Thomas Fox - Compliance Evangelist

Preparing for an Investigation

The Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), under Prong 7 Confidential Reporting and Investigation asks the following: Properly Scoped Investigation by Qualified Personnel – How...more

Sheppard Mullin Richter & Hampton LLP

DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs in Federal Fraud Investigations

On February 8th, the U.S. Department of Justice (DOJ) quietly issued new guidance on how the agency evaluates corporate compliance programs during fraud investigations. The guidance, published on the agency’s website as the...more

Thomas Fox - Compliance Evangelist

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

Thomas Fox - Compliance Evangelist

Forecasting, Risk Management and Compliance

When I was in the corporate world, I cannot begin to recall the number of times senior management had an overly optimistic forecast regarding some transaction; whether the transaction was the purchase of a smaller company, a...more

Thomas Fox - Compliance Evangelist

Wells Fargo Week: Part V – Compliance is the Answer

I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more

Fenwick & West LLP

SEC Announces $30 Million Whistleblower Award to Non-U.S. Resident

Fenwick & West LLP on

On Monday, September 22, 2014, the SEC announced that it expected to award between $30 and $35 million to a non-U.S. whistleblower who provided the SEC with information about “an ongoing fraud that would have been very...more

K&L Gates LLP

Global Boardroom Risk Solutions Newsletter

K&L Gates LLP on

Now more than ever, there is a need for risk solutions in the boardroom. Any organization can be faced with a significant crisis, whether a fraud investigation, a regulatory infringement, allegations of anticompetitive...more

Morgan Lewis

Fraudulent Receipts Pose Risks for Multinationals Operating in China

Morgan Lewis on

Multinational companies operating in the country should adapt their compliance programs in light of the risk of civil and criminal penalties. Fraudulent official receipts — or "fapiao"(the Chinese word for an official...more

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