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Policies and Procedures Foreign Corrupt Practices Act (FCPA) Department of Justice (DOJ)

Ankura

Balancing Courtesy and Compliance: Best Practices in Corporate Hospitality

Ankura on

Whether part of local customs, relationship building or ways to give thanks, gift giving and hospitality (collectively referred to here as “Hospitality”) is a sizable business, with the global market being estimated at USD839...more

Venable LLP

Is Your Company's Overseas Bribery Prevention Program Still Necessary Under Trump's DOJ?

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A recent executive order (EO) and Department of Justice (DOJ) policy statement issued in the first weeks of February signal a potentially dramatic shift in the DOJ's approach to enforcing the Foreign Corrupt Practices Act...more

NAVEX

The Importance of Benchmarking Your Compliance Program

NAVEX on

Sometimes questions about corporate compliance programs can be more complicated than they first seem. Such was the case when a compliance officer recently asked me, “Can you point to anything specific that says why compliance...more

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

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Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Program - March 13th - 14th, Mexico City, Mexico

ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more

Guidepost Solutions LLC

DOJ Maintains Interest in Bribery in Mexico and Latin America

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

ArentFox Schiff

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

ArentFox Schiff on

On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

Dechert LLP

Sanctions are “the New FCPA”: A Heightened Focus for DOJ Enforcement

Dechert LLP on

At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

A Primer on Policies and Procedures

Today, I conclude my five-part series on a Primer on FCPA Compliance. I end with a piece on policies and procedures. There are numerous reasons to put some serious work into your policies and procedures. They are certainly a...more

Thomas Fox - Compliance Evangelist

Fit for Purpose: Taking Compliance Internal Controls to the Next Level

Ed. Note-today we have a guest post from Troy McAlister, who brings 20 years of experience at both public and private companies, in public accounting and in a variety of industries. Troy has experience in establishing and...more

Thomas Fox - Compliance Evangelist

Welcome of 31 Days to a More Effective Compliance Program for September – Internal Controls

It is a new month and a new topic for 31 Days to a More Effective Compliance Program. In September, I will consider internal controls. I am pleased to welcome back Affiliated Monitors, Inc. (AMI) as this month’s sponsor of...more

Thomas Fox - Compliance Evangelist

A Tribute to Bill Yeoman: Compliance Metrics For a Board

Bill Yeoman died this week. You have to be a knowledgeable fan of college football to recognize that name as he retired in 1986. He was the head coach for the University of Houston (UH) Cougars for 25 years. His contributions...more

NAVEX

3 Ways to Apply New DOJ Guidance to Antitrust Compliance

NAVEX on

The Justice Department gave compliance officers a significant piece of guidance in June with its latest update to the evaluation of corporate compliance programs. The guidance begs the fundamental question: Is the compliance...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

White & Case LLP

DOJ Updates Guidance on Evaluation of Corporate Compliance Programs

White & Case LLP on

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

American Conference Institute (ACI)

[Event] 14th Forum on the Foreign Corrupt Practices Act - January 29th - 30th, Houston, TX

For more than a decade, this event has been regarded as a key networking and benchmarking forum for the anti-corruption community....more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

Ballard Spahr LLP on

The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more

American Conference Institute (ACI)

[Event] 8th Asia Pacific Summit on Anti-Corruption Singapore - October 16th - 17th, Singapore

American Conference Institute’s 8th Asia Summit on Anti-Corruption stands apart as one of the best networking and compliance benchmarking opportunities in the APAC region. Each year, senior government officials from...more

WilmerHale

DOJ Issues Updated Guidance on Evaluation of Corporate Compliance Programs

WilmerHale on

On April 30, 2019, the Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced an update to the Department of Justice’s (“DOJ”) 2017 guidance document entitled Evaluation of Corporate Compliance...more

Holland & Knight LLP

DOJ's Updated Compliance Guidance is Important for Healthcare Entities

Holland & Knight LLP on

• The U.S. Department of Justice (DOJ) recently updated its guidance to Criminal Division prosecutors in evaluating a corporation's compliance program when making charging decisions (Guidance). • The Guidance directs...more

The Volkov Law Group

Petrobas Closes Out “Massive” Corruption Investigations and Litigation

The Volkov Law Group on

When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more

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