Testing Your Compliance Program
Regulatory vs. Business Compliance
Grupo Empresarial y Control … ¿a qué te cojo ratón?
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Episode 342 -- How to Conduct an Internal Compliance Site Visit and Review
Enhancing Compliance: The Power of Independent Monitorships in Consumer Protection — Regulatory Oversight Podcast
Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Compliance into the Weeds: Of Fat Fingers, Internal Controls and Compliance
Vicky Hanks of Blake Morgan on Building an Effective Employee Brand - Passle's CMO Series Podcast
Better Investigative Interviewing
Hot Topics in International Trade
Episode 301 -- Steve Naughton on Compliance and Complaince Education at Loyola Law School Program
Episode 298 -- Electronics Communications Risks and Ephemeral Messaging
Episode 297 -- Susan Divers on LRN's 2023 Program Effectiveness Report
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
JONES DAY TALKS®: The Evolution of Corporate Compliance Programs: Key Issues for Multinational Companies
Compliance & Disaster Preparedness
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Our White Collar, Government & Internal Investigations Team examines the impact of President Trump’s Executive Order pausing enforcement of the Foreign Corrupt Practices Act and identifies some key considerations and...more
I had many ideas for an article that would expand on recent developments in the compliance and ethics space. My working title was the creatively light “Recent Developments.” But after meeting with SCCE & HCCA’s editorial...more
The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more
The Court holds that the Securities and Exchange Commission ("SEC") can continue to seek disgorgement from wrongdoers, while narrowing the remedy to net profits that are returned to victims. In Liu v. SEC, 591 U.S. ___...more
On June 1, 2020, the US Department of Justice ("DOJ") published an updated version of its guidance on the "Evaluation of Corporate Compliance Programs" (the "Guidance"), which was first published in February 2017. When...more
Please join McDermott and Grant Thornton on Thursday, May 28, for a webinar training on anti-corruption and compliance. This training will discuss the auditing standards on illegal acts by clients and the auditor’s...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It also requires companies whose securities are listed in the US to make and keep...more
Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more
This is a tough posting – frankly, there are so many lessons learned from the Walmart case that they could fill a book, or an e-book at least. I will focus on some of the big issues....more
I am at the end of this exploration of the Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action. This massive case came in with multiple documents, a long list of instances of bribery and corruption,...more
The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced last week. This massive case came in with multiple documents, a long list of instances of bribery and corruption, a...more
The Walmart case, from a big picture standpoint, represents a serious warning to all global companies committed to rapid international growth. In the absence of a significant and sustained commitment to compliance, rapid...more
Our long national nightmare is over – President Gerald Ford, August 9, 1974 - So, $900 million and roughly 8 years later, DOJ and the SEC announced the end of the Walmart FCPA enforcement action. (DOJ and SEC). The...more
June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more
The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more
We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more