News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Settlement Enforcement Actions

Baker Donelson

DOJ Dismisses FCPA Charges Against Former Cognizant Executives Following New Policy

Baker Donelson on

On April 2, 2025, the U.S. Department of Justice (DOJ) moved to dismiss the Foreign Corrupt Practices Act (FCPA) case against former Cognizant Technology Solutions Corp. executives Gordon Coburn and Steven Schwartz, United...more

Perkins Coie

Trump Halts FCPA Enforcement, for Now, and Appears to Open Pathway to Reexamine Prior FCPA Settlements

Perkins Coie on

The Foreign Corrupt Practices Act (FCPA), passed in the wake of Watergate, prohibits U.S.-linked companies and individuals from bribing foreign government officials to procure international business and hiding the bribes in...more

The Volkov Law Group

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

The Volkov Law Group on

On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more

The Volkov Law Group

BIT Mining FCPA Settlement and Lessons Learned (Part III of III)

The Volkov Law Group on

Bit Mining, formerly 500.com, was a doomed company from the beginning, When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2024

Bass, Berry & Sims PLC on

You are reading the November 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -...more

The Volkov Law Group

Raytheon’s FCPA and ITAR Case (Part III of IV)

The Volkov Law Group on

Raytheon’s comprehensive settlement included FCPA violations and failures to make required disclosures to the Defense Department concerning fees and commissions. This portion of the settlement was filed in the Eastern...more

The Volkov Law Group

Raytheon Reaches Comprehensive Settlement with Justice Department and Pays $950 Million to Resolve False Claims Act, FCPA and ITAR...

The Volkov Law Group on

Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a...more

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: March 1, 2024

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

The Volkov Law Group

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

The Volkov Law Group on

The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement.  While I have questioned DOJ’s commitment to its...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 10, Getting to Self-Disclosure: Speak Up, Triage and Internal...

Over this series, I have reviewed the messages communicated by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) from three key Foreign Corrupt Practices Act (FCPA) enforcement actions regarding...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 9, Internal Controls

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

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

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 6, Clawbacks and Holdbacks

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

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 4, Start with a Root Cause Analysis

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

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 5, Data Analytics

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

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

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

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 1, Self-Disclosure

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

Cadwalader, Wickersham & Taft LLP

Insider Trading in Physical Commodities

On December 14, 2023, the Commodity Futures Trading Commission (“CFTC”) and Department of Justice (“DOJ”) Fraud Section announced the settlement of insider trading fraud charges and Foreign Corrupt Practices Act (“FCPA”)...more

The Volkov Law Group

DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II)

The Volkov Law Group on

The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to explain why this slowdown occurred....more

The Volkov Law Group

Lessons Learned from the Tysers Insurance Brokers and H.W. Wood Limited FCPA Settlements (Part III of III)

The Volkov Law Group on

The Tysers and Wood FCPA settlements reflect something old and something new in the FCPA enforcement world. On the old side, at the core of the FCPA violations was the critical role played by the intermediary company....more

The Volkov Law Group

Two UK Reinsurance Brokers Settle with DOJ for FCPA Violations in Ecuador (Part I of III)

The Volkov Law Group on

DOJ announced two recent FCPA settlements with U.K. based reinsurance brokers involving a long-running bribery scheme involving two Ecuadoran state-owned insurance companies.  While DOJ has had a slow year in FCPA...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 1 – Background

Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

The Volkov Law Group on

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

The Volkov Law Group on

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

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