The Honeywell FCPA settlement underscored a number of important issues – lessons learned for compliance professionals. Every FCPA case carries important lessons learned, but some more than others....more
The facts surrounding Honeywell’s bribery schemes in Brazil and Algeria are fairly straightforward. In Brazil, the facts underscore the significant risks of bribery when companies participate in large, valuable project...more
The Justice Department and the Securities and Exchange Commission had a strong FCPA enforcement year. However, there is certainly more to come and it is easy to predict that 2023 will be even a bigger year....more
False Claims Act (FCA) cases, particularly in the government contracts space, often have several defendants; prime contractors, subcontractors, vendors and individuals are all common targets. In healthcare FCA cases, with...more
1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties- Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department...more