News & Analysis as of

Fraud Foreign Corrupt Practices Act (FCPA) Corporate Counsel

Fraud is the making of false representations or engaging in deceptive behavior in order to unlawfully secure financial or personal gain. 
Hinshaw & Culbertson - Consumer Financial...

An In-House Compliance Guide for Responding to President Trump's Executive Order on Foreign Corrupt Practices Act Enforcement

As has widely been published, on February 10, 2025, President Trump signed Executive Order (EO) 14209, which paused all future investigations and enforcement actions under the Foreign Corrupt Practices Act (FCPA) for at least...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2025

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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2024

Morrison & Foerster LLP on

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

Cozen O'Connor

DOJ Signals Increased Emphasis on Data Analytics to Prosecute FCPA Global Corruption

Cozen O'Connor on

On November 29, 2023, Department of Justice (DOJ or Department) policymakers announced explicitly that they are, for the first time, leveraging data analytics to help proactively identify and prosecute crimes in foreign...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

Foley Hoag LLP - White Collar Law &...

First Circuit Narrows Whistleblower Protections of Sarbanes-Oxley

On July 13, 2022, the United States Court of Appeals for the First Circuit ruled that the whistleblower protections contained in Section 806 of the Sarbanes-Oxley Act (SOX) do not apply to employees who report potential...more

Vinson & Elkins LLP

Biden’s 2023 Budget Showcases DOJ Enforcement Priorities and Heightened Government Interest in Prosecuting Antitrust,...

Vinson & Elkins LLP on

A review of President Biden’s proposed Budget (“Budget”) for 2023 spotlights the enforcement priorities of the president’s Justice Department as the administration enters its third year. ...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for February 2022

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

Morrison & Foerster LLP - Government...

Top 10 International Anti-Corruption Developments for February 2019

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for June 2018

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for February 2018

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Thomas Fox - Compliance Evangelist

First 100 Days of the Trump Administration and The FCPA – Same As It Ever Was

Over the weekend, we had the first 100 days of the Trump administration. To commemorate this constructed time for review of any new administration I gathered the Everything Compliance podcast panel of Mike Volkov, Jay Rosen,...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for February 2017

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

BakerHostetler

Foreign Corrupt Practices Act 2016 Year-End Update

BakerHostetler on

2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more

Thomas Fox - Compliance Evangelist

Recidivism Under the FCPA: Zimmer Biomet

Last week Zimmer Biomet Holdings, Inc. paid a high price for its and its predecessors failure to comply with the terms and conditions of 2012 Deferred Prosecution Agreement (the “2012 DPA”). Biomet, having originally paid $23...more

Thomas Fox - Compliance Evangelist

When the Compliance Counsel Speaks, CCOs Should Listen

I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more

Orrick, Herrington & Sutcliffe LLP

New FCPA Guidance: DOJ Swings and Misses

On April 5, 2016, the Fraud Section of the Criminal Division, Department of Justice ("DOJ") released a policy document entitled, The Fraud Sections' Foreign Corrupt Practices Act Enforcement Plan and Guidance ("Guidance"), in...more

Dorsey & Whitney LLP

For FCPA Compliance, Tone At The Top Key, Lack of Policies A Difficulty

Dorsey & Whitney LLP on

The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more

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