Episode 116 -- Alstom Executive Convicted of FCPA and Money Laundering Offenses
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
Bribery & Corruption in the Military. A Front-Line View (Part II)
FCPA Compliance and Ethics Report-Episode 130, The Oscars and Compliance, Part IV with Jay Rosen
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II
Thinking Compliance When Protecting Your Ideas Internationally
FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor
Fine Tuning Your Anti Corruption Compliance Program
The FCPA Compliance and Ethics Report, Episode 3
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
The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...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
Compliance officers are trained to spot risks. They have an eagle eye and keen sensitivity. In some cases they have to overcome inaccurate designations – my favorite is a “PEP,” a politically exposed person. ...more
Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more
My question appears to be fairly obvious, right? This is not a question or a quiz of every chief compliance officer. Rather, this is a question for everyone but the CCO and compliance and legal staff. Think about it....more
On April 29, 2016, the Supreme Court of Canada ruled unanimously in World Bank Group v. Wallace that documents from World Bank Group investigations remain immune from document production requests that are part of domestic...more
When recently I contacted the Underworld about the potential listing of this vast property, I was stunned when Satan himself answered the phone. While I was tempted to ask what happened to all his hired help down there,...more
Welcome to the August 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more
In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around its hiring of sons and...more
Yesterday the Securities and Exchange Commission (SEC) announced a resolution with Bank of New York Mellon Corporation (BNY Mellon) for violations of the Foreign Corrupt Practices Act (FCPA). This was the first enforcement...more
Can you get a sense of place from listening to a song? In an article in the Financial Times (FT), entitled “The Life of a Song – Georgia On My Mind”, Mike Hobart wrote that when you “combine Stuart Gorrell’s lyrics with Hoagy...more
Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between...more
Moe Green died again yesterday but this time he was not shot through the glasses, it was from cancer and the fictional Las Vegas mobster lived to the ripe old age of 79. Of course I am referring to “Alex Rocco, the veteran...more
The DOJ resolved another FCPA action with the company entering into a deferred prosecution agreement, paying a criminal fine and agreeing to the imposition of a monitor after self reporting and cooperating. Two of the firm’s...more
On June 16, 2015, IAP Worldwide Services Inc., a private defense and government contracting company, agreed to pay $7.1 million to settle criminal charges of the U.S. Foreign Corrupt Practices Act (FCPA) related to bribing...more
In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more
In this episode I review the BHP Billiton FCPA enforcement action brought by the Securities and Exchange Commission. I review the underlying facts and provide some lessons learned for the compliance practitioner. The key...more
So, we have covered the Foreign Corrupt Practices Act’s (“FCPA”) scope, but the FCPA anti-bribery provisions also contain certain exceptions and affirmative defenses. These exceptions and affirmative defenses attempt to carve...more
When does bribery and corruption move from a business issue to a political issue to a national issue? Why should US companies be held to the gold standard of anti-corruption laws? Should the US government even care if US...more
For years, we have all heard about the coming wave of FCPA enforcement against financial institutions, investment banks, private equity firms and others who interact with sovereign wealth funds overseas....more
I am often asked about franchisor liability under the Foreign Corrupt Practices Act (FCPA). Franchising has been a successful model in the US and now many corporations are looking at overseas expansion opportunities....more
In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more
In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more
Companies are increasingly seeking international protection for their intellectual property, but in doing so their interaction with foreign government agencies increases. Because of increased scrutiny on corporate compliance...more