Upping Your Game: Episode 1 – Meeting Hui Chen’s Challenge
FCPA Compliance Report: From Compliance to Commercial Value: Removing Friction with AI
Daily Compliance News: April 28, 2025, The Santos Sobs Edition
FCPA Compliance Report: Ellen Hunt on Compliance ROI and on a Due Diligence and the US Sentencing Guidelines
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
FCPA Compliance Report: Kristy Grant-Hart on A 360° Review of the Future of Compliance
Episode 365 -- Four Sanctions Cases Everyone Should Know
FCPA Compliance Report: AI, Data Compliance, and Ownership - A Conversation with Andrew Hopkins
2 Gurus Talk Compliance: Episode 49 - The Depression Episode
10 For 10: Top Compliance Stories For The Week Ending April 5, 2025
Daily Compliance News: April 3, 2025, The Tribute to Ice Edition
Compliance into the Weeds: The Role of Compliance Going Forward
Daily Compliance News: March 27, 2025, The Eliminate the District Courts Edition
Great Women in Compliance: The Future of Enforcement with Jennifer Lee
FCPA Compliance Report: Navigating the Complexities of FTO Designations and Compliance in Mexico and Latin America
Regulatory Ramblings: Episode 65 – The Trump Administration’s Decision to Halt FCPA Enforcement – The Implications for Asia and the World with Tom Fox, Malcolm Nance, and Philip Rohlik
FCPA Compliance Report: Celebrating the 2025 World’s Most Ethical Companies: Highlights with Erica Salmon Byrne
10 For 10: Top Compliance Stories For the Week Ending March 15, 2025
Compliance into the Weeds: More Compliance Challenges in the Trump Era
Daily Compliance News: March 12, 2025, The Ruth Marcus Resigns Edition
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
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more
If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that after 40 years of the FCPA, companies might follow its prescriptions...more
Herbalife’s FCPA settlement is another one for books – the wreckage left includes two criminal indictments for Chinese officials who may never be apprehended, along with $123 million in penalties....more
- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more
On July 3, 2020, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) jointly released the second edition of the “Resource Guide to the U.S. Foreign Corrupt Practices Act,” which was...more
Innovation in compliance can come in many forms. One such form was described by Vincent M. Walden, Managing Director at Alvarez and Marsal Holdings, LLC (A&M), in his article entitled “Profit & Loss-of-One”(P&L-of-One). In...more
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
A key analysis is whether there are controls in place to enforce the policies and whether those controls are documented. To help to answer this query, there are four issues to evaluate...more
Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive...more
Last week, DOJ announced the indictment of two former Herbalife executives in China for participating in a bribery scheme over a ten-year period. Herbalife, a multi-level marketing company, was not charged and its...more
Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China. Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil...more
The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies. ...more
“Microsoft’s subsidiary in Hungary provided discounts on software licenses to its resellers, distributors and other third parties. Instead of passing on the discounts to Microsoft’s government customers, the discounts were...more
As the old adage provides – better late than never. (Same applies for my somewhat tardy posting on this case). Telefônica Brasil settled FCPA violations with the SEC for a pretty penny — $4.125 million in civil penalties...more
In a number of enforcement contexts, I am always struck by a common theme – crooks are able to obtain access to corporate money for improper purposes. You never hear about a crook who uses his own money to pay bribes or...more
When you read through the United Technologies SEC FCPA enforcement action, you cannot help but shake your head – the level of abuse and participation by senior managers in the UT companies – Pratt & Whitney and Otis Elevator...more
The laundry list of companies that have been prosecuted for FCPA violations surrounding gifts, meals, entertainment and travel expenditures is lengthy....more
Rock and roll heaven got another power player this week as Greg Lake died on December 7th. He was one-third of the greatest prog rock trio Emerson, Lake & Palmer (aka ELP). With apologies to Patrick Hays and all you...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program around FCPA enforcement as this week there where two public declinations...more
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for another posting on corruption risks in China. A little fear is healthy. It will keep you vigilant and aware. At this point if corporate...more
On March 1, 2016, the SEC announced that Qualcomm Incorporated, a San Diego-based wireless telecommunication product company, agreed to pay $7.5 million to settle charges that its actions violated the Foreign Corrupt...more
The Commission prevailed on a summary judgment motion this week in a case based on an offering fraud. It also filed another settled FCPA action centered on gifts, travel and entertainment provided to healthcare professionals...more