News & Analysis as of

Fraud Foreign Corrupt Practices Act (FCPA) Corruption

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 
Benesch

White Collar Quarterly Report - August 2024

Benesch on

In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...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

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Thomas Fox - Compliance Evangelist

The DOJ on the Need for Compliance Program Data Analytics

The Department of Justice (DOJ) is increasingly utilizing data analytics for proactive enforcement, signaling a significant shift in their approach to combating white-collar crime. This move reflects the recognition of data...more

Ballard Spahr LLP

DOJ Bolsters International Cooperation to Combat Corruption

Ballard Spahr LLP on

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

Wilson Sonsini Goodrich & Rosati

Goal Disallowed: Court Rules in FIFA Corruption Case that U.S. Prosecutors Cannot Use Fraud Statute to Tackle Foreign Commercial...

It is no surprise that the United States’ fight against corruption is not confined to its borders. For decades, the government has sought to prosecute individuals and companies across the globe who have been involved in...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for February 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...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

King & Spalding

H2 2021: Latin America Enforcement Review

King & Spalding on

To close out 2021, enforcement authorities throughout the Americas continued to investigate fraud, corruption, and other misconduct across the region. For 2022, we expect an uptick of anticorruption investigations as a...more

Morgan Lewis

DOJ Ramping Up Fraud Enforcement Efforts: 2021 Year in Review Report

Morgan Lewis on

The US Department of Justice’s Criminal Division Fraud Section released its annual Year in Review report on February 15, covering 2021. Despite ongoing aftershocks associated with the global pandemic, this year’s report...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

Jenner & Block on

Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

The Volkov Law Group

Credit Suisse’s Global Bribery and Fraud Scheme (Part II of II)

The Volkov Law Group on

The Credit Suisse case highlights the significant impact that global corruption and fraud can have on developing economies.  Mozambique’s economy suffered serious harm from the scheme, which started to unravel when the IMF...more

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

Kohn, Kohn & Colapinto LLP

Will Europe Fail to Protect Whistleblowers?

Pursuant to a Directive enacted by the European Parliament and Council, all 27 nations within the European Union (EU) must “bring into force” whistleblower protection “laws, regulations and administrative provisions” by...more

Society of Corporate Compliance and Ethics...

Gary Kalman on Corruption and Compliance Programs

The playing field for anticorruption never stops changing, with new laws and new risks constantly arising. To help sort things out, and to gain his insight into other compliance challenges, we sat down with Gary Kalman,...more

Porter Hedges LLP

New Action By The CFTC Means Higher Stakes For Commodity Market Participants

Porter Hedges LLP on

The Commodity Futures Trading Commission (“CFTC”) recently announced the settlement of its first enforcement action involving foreign corruption. In December 2020, the CFTC issued a Consent Order, finding that Houston-based...more

WilmerHale

CFTC 2020 Enforcement and Regulatory Developments and a Look Forward

WilmerHale on

2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

The Volkov Law Group on

Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more

King & Spalding

Q4 2020: Latin America Enforcement Review

King & Spalding on

As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. Below, we highlight some developments from...more

Orrick, Herrington & Sutcliffe LLP

CFTC Charges an Energy Company and its Employee with Foreign Corruption

In a coordinated enforcement action with the DOJ, the CFTC filed and simultaneously settled charges against Vitol Inc., the U.S. affiliate of one of the world’s largest energy trading firms. ...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Herbalife FCPA Enforcement Action

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to...more

The Volkov Law Group

Three Individuals Charged with Fraud and FCPA Violations in International Adoption Scheme

The Volkov Law Group on

FCPA cases can arise in un usual situations.  DOJ has focused two separate prosecutions on bribery and fraud involving adoptions from Uganda and Poland.  At the heart, the defendants bribed Ugandan and Polish authorities to...more

Thomas Fox - Compliance Evangelist

Executives Acting in Bad Faith and the Role of the Board

A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more

Gray Reed

2019 Bad Guys in Energy

Gray Reed on

To our bad guys, 2019 was a year flush with hope and opportunity; it ended with recidivism, more misery from Venezuela, a charlatan, an Okie who pulled a multi-million dollar fast-one on Chesapeake and, as in years past, a...more

Thomas Fox - Compliance Evangelist

Frosty the Snowman, the Eyes of Dr. Eckleburg and Leissner – Lessons Learned

I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. Yesterday, I begin a two-part blog post series on Leissner’s settlement with...more

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