Popular, Enforcement Actions, Foreign Corrupt Practices Act (FCPA)

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

The Volkov Law Group on 9/4/2024

The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more

FCPA Survival Guide - Step 8 - Investing in Compliance

Thomas Fox - Compliance Evangelist on 7/25/2024

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo outline the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a complete declination. All...more

FCPA Survival Guide: Step 3 - Extensive Remediation

Thomas Fox - Compliance Evangelist on 6/13/2024

How can you survive an FCPA enforcement action? In this special podcast series, Tom Fox and Nick Gallo lay out the Top 10 things you can do to reduce your overall fine and penalty, perhaps down to a full declination. All of...more

China Draws Scrutiny as US Regulators Renew Anti-Bribery and Corruption Enforcement Focus

McDermott Will & Emery on 4/23/2024

Recent bribery and corruption enforcement efforts by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC), combined with new legislative and policy initiatives, including last December’s passage...more

Compliance into The Weeds: Trafigura FCPA Enforcement Action

Thomas Fox - Compliance Evangelist on 4/3/2024

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

[Event] The Brazil Summit on Anti-Corruption, Integrity & ESG - May 22nd - 23rd, São Paulo, Brazil

American Conference Institute (ACI) on 3/27/2024

Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more

Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement

The Volkov Law Group on 3/24/2024

In a recent blockbuster FCPA settlement, DOJ announced a $661 million resolution with Gunvor, one of the world’s largest commodities trading companies. DOJ’s settlement represents a “return” to its long-standing aggressive...more

Top 10 International Anti-Corruption Developments for February 2024

Morrison & Foerster LLP on 3/20/2024

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

2023 Sanctions Year in Review and Predictions

The Volkov Law Group on 1/23/2024

As always, I tend to repeat myself. However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals. DOJ has...more

Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action

Thomas Fox - Compliance Evangelist on 1/17/2024

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

SAP Returns to U.S. Enforcement Scene: Pays DOJ and SEC Over $220 Million to Resolve FCPA Violations (Part I of III)

The Volkov Law Group on 1/16/2024

Life is always filled with surprises. Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South...more

The SAP FCPA Enforcement Action-Part 2: The Box Score of Corruption

Thomas Fox - Compliance Evangelist on 1/16/2024

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement involving the German software company, SAP. The company agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission...more

2024 Regulatory, Compliance, and Enforcement Predictions for Life Sciences Companies

Morrison & Foerster LLP on 1/10/2024

The year 2023 was a busy one for regulatory, compliance, and enforcement developments in the healthcare and life sciences industries, and 2024 promises to be even busier. We tapped MoFo’s Life Sciences + Healthcare Compliance...more

Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III)

The Volkov Law Group on 10/3/2023

Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries. However, as usual,...more

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

The Volkov Law Group on 9/28/2023

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

All Things Investigations: Episode 36 – The 3M FCPA Enforcement Action and Opinion Release 23-01 with Mike DeBernardis

Thomas Fox - Compliance Evangelist on 9/11/2023

In this episode of All Things Investigations, host Tom Fox delves deep into the significant enforcement action by the SEC against 3M in China with guest Mike DeBernardis. The action revolves around the provision of covert...more

Gartner Settles FCPA Case with SEC for $2.5 Million

The Volkov Law Group on 5/30/2023

The SEC has been racking up several FCPA enforcement actions. DOJ appears to be declining many of these cases. The division of enforcement appeared to follow a pattern – on larger cases with more pervasive violations, DOJ...more

Wells Fargo Fined $97.8 Million for Failing to Identify Sanctions Violations From a Legacy Wachovia Business

Kramer Levin Naftalis & Frankel LLP on 4/4/2023

On March 30, federal regulators announced that Wells Fargo Bank had entered into settlements in which it agreed to pay $97.8 million in fines for enabling sanctions violations between 2010 and 2015. In two separate...more

One Month to More Effective Compliance on Business Ventures - Day 21 - Distributor Liability Under the FCPA

Thomas Fox - Compliance Evangelist on 3/29/2023

Three enforcement actions made clear that there were no distinctions between agents and distributors. They were the Smith & Nephew, Inc., Oracle (2012 and 2022), and Eli Lilly and Company. Each of these enforcement actions...more

One Month to More Effective Compliance on Business Ventures - Day 02 - Key M&A cases under the FCPA

Thomas Fox - Compliance Evangelist on 3/2/2023

What are some of the key FCPA enforcement actions involving M&A? These enforcement actions, the FCPA Resource Guide, and the Evaluation of Corporate Compliance Program (and Update) have all made clear that the DOJ and SEC...more

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

American Conference Institute (ACI) on 2/22/2023

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

DOJ Charges Two Oil and Gas Traders with FCPA Bribery Scheme Involving Petrobras

The Volkov Law Group on 2/21/2023

In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras...more

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

Thomas Fox - Compliance Evangelist on 1/3/2023

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

The Corruption Files - Episode 15 - The ABB Settlement

Thomas Fox - Compliance Evangelist on 1/3/2023

Establishing a trust can greatly affect the outcome of a case. Tom Fox and Michael DeBernardis talk about ABB’s 2022 bribery case in South Africa, how self-disclosure benefits any situation, the DOJ’s approach to cracking...more

ABB FCPA Resolution: Part 5 – A Win for Compliance

Thomas Fox - Compliance Evangelist on 12/9/2022

We conclude our exploration of the latest resolution of a Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. There have been several reference documents used this week and they...more

Today's Popular Updates › Enforcement Actions › Foreign Corrupt Practices Act (FCPA)

"My best business intelligence, in one easy email…"