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Government Officials Foreign Corrupt Practices Act (FCPA)

Thomas Fox - Compliance Evangelist

Key Compliance Speeches from 2023 - Kenneth Polite on Incentives and Consequence Management

Assistant Attorney General Kenneth A. Polite, Jr. began his speech with an interesting aside. It is about the clear tie between poverty and corruption. This is why it is important to prosecute corrupt government officials...more

Wilson Sonsini Goodrich & Rosati

What Companies Can Learn from the FirstEnergy/Ohio GOP “Dark Money” Scandal

In June, two prominent Ohioans were sentenced for their involvement in one of the largest political scandals in Ohio’s history. Former Speaker of the Ohio House of Representatives Larry Householder and former Chair of the...more

The Volkov Law Group

Catching Up with FCPA News

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DOJ closed out its FCPA enforcement year in 2022 with two significant settlements, the ABB and Honeywell cases.  Aside from these two big settlements, there was a flurry of other actions in the last quarter of 2022....more

Kramer Levin Naftalis & Frankel LLP

United States v. Hoskins

On Aug. 12, 2022, the Court of Appeals for the Second Circuit issued an important decision regarding the scope of the Foreign Corrupt Practices Act’s (FCPA) application to non-U.S. citizens who are employed by foreign...more

The Volkov Law Group

KT Corp’s Bribery Schemes (Part II of III)

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When you look under the hood of FCPA enforcement actions, the schemes employed by corporate actors can be shocking. The “creativity” of bad actors can provide important lessons learned and help future investigators when...more

Hogan Lovells

The UK's “revolving door” culture is relatively unregulated – but is change on the horizon?

Hogan Lovells on

On 1 November 2021, the independent Committee on Standards in Public Life published a report recommending sweeping changes to lobbying rules in the UK. The Committee’s 103-page report contains resounding criticisms of the...more

The Volkov Law Group

Former Ericsson Employee Indicted for Role in Foreign Bribery Scheme

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In a surprising (but fully warranted) twist, the Justice Department returned an indictment against a former employee of Telefonaktiebolaget LM Ericsson (“Ericsson”), a global telecommunications company, for his role in paying...more

K&L Gates LLP

Voluntary Disclosure - Special Edition - A Debrief on the 37th International Conference on the Foreign Corrupt Practices Act

K&L Gates LLP on

White collar practitioners Neil Smith, William Semins, Nicole Stockey, and David Peet discuss their key takeaways from this year’s 37th International Conference on the Foreign Corrupt Practices Act....more

McDermott Will & Emery

[Webinar] 2020 Latin American Compliance Conference - November 19th, 12:15 pm - 2:00 pm EST

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Join us virtually for a Latin American Compliance Conference where senior government officials, industry experts and key US and Latin American lawyers discuss anti-corruption and Foreign Corrupt Practices Act (FCPA)...more

Thomas Fox - Compliance Evangelist

J&F – The Bribery Schemes

Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The FCPA Enforcement Action

Recently we saw one of the most blatant cases of bribery and corruption brought by the Department of Justice (DOJ) in the form of a guilty plea by Sargeant Marine Inc. (Sargeant Marine), an asphalt company, related to...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 2 – Bribery Schemes and Numbers

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 1 – Introduction

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

The Volkov Law Group

DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama

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DOJ announced the arrest of two individuals, Luis Martinelli Linares and Ricardo Martinelli Linares, who are the sons of the former President of Panama, Ricardo Martinelli) for their role in funneling $28 million in bribes to...more

The Volkov Law Group

Three Former Executives from Alstom and Marubeni Charged with Criminal FCPA Violations in Indonesia

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In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more

A&O Shearman

Airbus Agrees Record-Breaking €3.6 Billion Settlement to Avoid Prosecution

A&O Shearman on

On 31 January 2020, Airbus SE (Airbus) reached final agreements with the French Parquet National Financier (PNF), the U.K.’s Serious Fraud Office (SFO) and the U.S. Department of Justice (DoJ) in order to resolve...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 6 – The Investigation, the Remediation and Final Thoughts

Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 5 – The UK Judgment on the DPA

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

The Volkov Law Group

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

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When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 4 – Alphabet Agency Violations (Export Control and Export Finance)

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

The Volkov Law Group

Airbus ITAR Settlement: Review of Airbus ITAR Violations (Part III of IV)

The Volkov Law Group on

The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations.  Last year, Quad Graphics earned a declination for FCPA and OFAC violations.  In 2013, Weatherford settled...more

Jones Day

FCPA 2019 Year in Review

Jones Day on

In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 2 – The Paper Compliance Program

Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more

The Volkov Law Group

Airbus Agrees to Pay $4 Billion in Global Settlement of Foreign Bribery and ITAR Violations (Part I of IV)

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In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve...more

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