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Foreign Corrupt Practices Act (FCPA) Technology Sector Compliance

Thomas Fox - Compliance Evangelist

Upping Your Game: Episode 1 – Meeting Hui Chen’s Challenge

In February, the Trump Administration suspended investigations under and enforcement of the FCPA. Many compliance professionals have since wondered what this will mean for corporate compliance programs going forward. Hui Chen...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

American Conference Institute (ACI)

[Virtual Event] 37th International Conference on the FCPA - December 2nd - 3rd, 9:00 am - 4:30 pm EST

The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more

Latham & Watkins LLP

Current Developments in the US: White-Collar Enforcement and trends for 2020

Latham & Watkins LLP on

In the following article we will discuss the current developments and trends for 2020 and outline what EU-based companies with a US presence should look out for in 2020 regarding US white-collar and compliance trends in the...more

The Volkov Law Group

Antitrust Division Launches Broad Investigation of High-Tech Industry

The Volkov Law Group on

When it comes to the Justice Department and reading the tea leaves, I often rely on a very obvious point – DOJ tells you in advance what it is planning and then executes its plan.  This has been true in the FCPA arena,...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 5: Ringo and The End – Microsoft FCPA Settlement – Part 4

Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more

The Volkov Law Group

Microsoft FCPA Settlement Underscores Third-Party Risks (Part II of III)

The Volkov Law Group on

Microsoft’s bribery and controls violations reflect significant risks facing companies that rely on distributor and reseller networks to sell their products.  Companies often enter and operate in emerging markets through...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 4: In-A-Gadda-Da-Vida – Microsoft FCPA Settlement – Part 3

Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more

The Volkov Law Group

Microsoft Pays DOJ and SEC $25 Million to Resolve FCPA Violations (Part I of III)

The Volkov Law Group on

Microsoft finally resolved its FCPA enforcement action with a whimper.  Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 3: Los Endos and Microsoft FCPA Enforcement Action – Part 2 – The Bribery Schemes

Microsoft Hungary agreed to pay approximately $8.5 million to the DOJ. Together with the amounts paid to the SEC in profit disgorgement, the total is just over $25 million. Microsoft Hungary received a 25% discount off the...more

White & Case LLP

Does your compliance program address UK exposure?

White & Case LLP on

Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more

Thomas Fox - Compliance Evangelist

AI for Risk Management in Compliance – A New Business Advantage

There have been some articles recently which discussed the revolution of technology into compliance, specifically with the introduction of Artificial Intelligence (AI) into the profession. A few pieces claimed this was...more

Thomas Fox - Compliance Evangelist

Will Culture Change at Uber Before It’s Too Late?

What happens when a company delivers a superior product or service which is enthusiastically embraced by the consuming public, has a contented, if not equally enthusiastic, public facing work force and the business itself...more

The Volkov Law Group

Headlines from Mid-Year FCPA Enforcement Review

The Volkov Law Group on

Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines...more

Morrison & Foerster LLP

5 Takeaways From Former SAP Exec's FCPA Case

On Aug. 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International Inc.) pled guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act. In addition to pleading...more

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