News & Analysis as of

Foreign Official Dept. of Justice

The FCPA Week That Was — Seven Individuals Charged for FCPA Violations

by Michael Volkov on

To all the “nattering nabobs of negativity” concerning FCPA enforcement, the US Justice Department responded with a resounding message – not only is FCPA enforcement here to stay, but individual violators are on DOJ’s radar...more

In the Third-Largest FCPA Enforcement Action Ever, Telia Agrees to Pay Almost $1 Billion to Resolve Bribery Inquiry in Uzbekistan;...

by Ropes & Gray LLP on

In the first blockbuster FCPA action of the Trump administration, on September 21, 2017, Swedish telecommunications company Telia agreed to pay $965 million in total penalties to the U.S. Department of Justice (“DOJ”) and...more

Diwali: An Opportune Time for an Anti-Corruption Compliance Reminder

by Foley & Lardner LLP on

This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more

FCPA under the New Administration

by Blank Rome LLP on

The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more

Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce

by Michael Volkov on

After years of fits and starts, and promises and disappointments, the Serious Fraud Office and the UK Bribery Act made its initial splash on the anti-corruption enforcement landscape. Since 2011, companies have been...more

The FCPA Enforcement Run Continues into 2017

by Michael Volkov on

Just when we thought 2016 was over and we could all breathe a sigh of relief, DOJ and the SEC have continued to run with a string of new enforcement actions. To all of those prognosticators, paparazzi, commentators, chicken...more

Rolls-Royce Global Enforcement Action: Part I

by Thomas Fox on

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more

FCPA Predictions for 2017 (Part III of III)

by Michael Volkov on

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs...more

Shearman & Sterling’s Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest -...

by Shearman & Sterling LLP on

Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

T’Was the Week After Christmas: General Cable and Mexico Aviation FCPA Prosecutions

by Michael Volkov on

You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my...more

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

by Michael Volkov on

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

JPMorgan Sons and Daughters FCPA Enforcement Action, Part II

by Thomas Fox on

Today I will consider the superior result achieved by JPM in its FCPA resolution. Not only did it receive a 25% discount off the bottom of the US Sentencing Guidelines fine range but it received a NPA and not even a Deferred...more

Do You Know and Understand Your Compliance Policies?

by Michael Volkov on

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

A Cautionary Illustration of the Need for Accounting and Compliance Reviews

by Polsinelli on

Embraer SA, Brazil's flagship aerospace manufacturer and a worldwide competitor across various aviation markets, experienced first-hand the scope and reach of the Foreign Corrupt Practices Act (FCPA). Embraer agreed to pay...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

by Dechert LLP on

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)

by Michael Volkov on

The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions,...more

Three Key Questions to Ask in Hiring of Family Members of Foreign Officials

by Thomas Fox on

One of the top academic commentators in the anti-corruption space is Matthew C. Stephenson, co-founder of the Global Anticorruption Blog. I was intrigued by Stephenson’s piece, entitled “Does an FCPA Violation Require a Quid...more

LATAM/LAN FCPA Enforcement Action, Part I-Some Questions

by Thomas Fox on

What is the cost of a Foreign Corrupt Practices Act (FCPA) violation? One subset of that question is what is the cost of not cooperating and not remediating during the pendency of such investigations? Those were two of the...more

Froome Ends Tour With Win; JP Morgan to End Sons and Daughters Case?

by Thomas Fox on

I begin today’s post with a tip of the (cycling) helmet to Englishman Chris Froome who yesterday won his third Tour de France championship. Froome overcame a great many obstacles, not the least of which was being involved a...more

Doing Business Outside Of The US – Does Your Company Have An FCPA Policy? – The Perils Of International Bribery

The Foreign Corrupt Practices Act of 1977 (15 U.S.C. § 78dd-1, et seq.), more popularly known as the “FCPA,” is a powerful tool that the U.S. Department of Justice uses to police international bribery in the business context....more

Avoiding the “Al Capone” version of an FCPA enforcement action—Are your internal controls in order?

Notorious gangster Al Capone likely was guilty of numerous crimes, including bootlegging, maintaining a house of prostitution, bribery, racketeering and multiple counts of murder. Yet he was never convicted of those crimes. ...more

Foreign Corrupt Practices Act Alert

by WilmerHale on

Busy Q1 Yields Several Significant FCPA Resolutions - Overview - On February 19, during the US Securities and Exchange Commission’s (SEC) annual “SEC Speaks” conference, Kara Brockmeyer, Chief of the SEC’s FCPA...more

VimpelCom Ltd. Agrees to Pay $795M and Accept a Three-Year Corporate Monitor to Resolve Massive Bribery Scheme in Uzbekistan

by Ropes & Gray LLP on

On February 18, 2016, Amsterdam-based VimpelCom Ltd., the world’s sixth-largest telecommunications company, and its wholly owned Uzbek subsidiary, Unitel LLC, entered into agreements with the U.S. Department of Justice...more

Reflections on the Hitachi FCPA Enforcement Action

by Thomas Fox on

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

You’re the Man—Government Targets Individuals in FCPA Cases

by Fenwick & West LLP on

The government has increasingly focused its FCPA enforcement firepower on individuals. On August 31, a Russian official living in Maryland pled guilty to conspiracy to commit money laundering in connection with arranging $2...more

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