News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Risk Management Corruption

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

DLA Piper

From the US to Brazil: Tackling Corruption Risks in M&A

DLA Piper on

Corporate transactions, especially mergers and acquisitions (M&A), have become pivotal strategies for growth in an increasingly globalized economy. However, with this expansion comes the responsibility of navigating complex...more

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

Dorsey & Whitney LLP on

On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

NAVEX on

Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....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

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 8, Enhancing Your Compliance Program

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Managing Third Parties

The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more

Thomas Fox - Compliance Evangelist

Risk Assessments

One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

Littler on

While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...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

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

American Conference Institute (ACI)

[Event] 12th Summit on Anti-Corruption Brazil - May 24th - 25th, Sao Paulo, SP, Brazil

Hosted by American Conference Institute, the 12th Summit on Anti-Corruption Brazil returns for another exciting year with a newly revamped, truly interactive networking and benchmarking experience. In addition to critical...more

Thomas Fox - Compliance Evangelist

Reprioritizing Your Third-Party Risk Management Program-Risk Mitigation

With the ever-changing landscape of regulations and laws, it is becoming increasingly difficult for companies to keep up and remain compliant. In this 5-part blog post series, sponsored by Diligent, I will consider the full...more

American Conference Institute (ACI)

[Webinar] Anti-Corruption Brazil – FCPA Compliance and Enforcement in Brazil: DOJ and SEC Alumni Provide Critical Updates and the...

American Conference Institute’s expert faculty of DOJ and SEC alumni will update you with the most recent developments and risk factors confronting industry in Brazil and will lay out practical takeaways for satisfying the...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - May 8th - 11th, Chicago, IL

Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...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

NAVEX

Avoiding Bribery and Corruption: A Gift Giving Guide

NAVEX on

Gift-giving is common in many workplaces, especially during the holiday season. While giving your coworker or customer a present can help to build business relationships, not all forms of gift-giving happen with such...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - February 27th - March 2nd, Scottsdale, AZ

Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...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...

[Event] Basic Compliance & Ethics Academy - January 23rd - 26th, Lake Buena Vista, FL

Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 22nd - 25th, Las Vegas, NV

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

The Volkov Law Group

Adjusting Your Perspective — Identifying Your Real Third-Party Risks (Part II of V)

The Volkov Law Group on

Compliance professionals are always looking for ways to collaborate and support internal business partners.  Through the years, compliance professionals have devoted significant energy to building partnerships with the...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - May 16th - 19th, Boston, MA

Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more

Thomas Fox - Compliance Evangelist

KT Corp. FCPA Enforcement Action: Part 3 – Lessons Learned

This week I have been exploring the KT Corporation settlement Foreign Corrupt Practices Act (FCPA) with the Securities and Exchange Commission (SEC) via a Cease and Desist Order (the Order) for “disgorgement of $2,263,821,...more

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