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Risk Assessment Department of Justice (DOJ) Corruption

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

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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

Paul Hastings LLP

Sign on the Dotted Line: Compliance Certifications by CEOs and CCOs A Likely Requirement

Paul Hastings LLP on

As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...more

Guidepost Solutions LLC

The Looming Bear Market is Likely to Bring More Prosecutions

When the tide goes out, as it appears to be doing now with the market down 20% percent from its highs in January, bad actors will be left exposed for everyone to see. Simply put, as the market drops those companies hiding...more

The Volkov Law Group

CCOs and Criminal Cartel Compliance Programs (Part II of III)

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Chief compliance officers have plenty of things to do and risks to manage.  CCOs have a unique remit and a set of skills that should be applied whenever needed.  While I am not trying to increase CCO workload (and forgive me...more

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

Morgan Lewis on

In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

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While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

Thomas Fox - Compliance Evangelist

The Unaoil Execs Guilty Pleas - The Ahsanis Criminal Information

Nine years ago, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. ...more

K2 Integrity

China Emerging as an Increasing Driver of Global Illicit Finance Risk

K2 Integrity on

Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 4 – What Does it all Mean?

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

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

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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

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 7 – M&A

We conclude our 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...more

Kramer Levin Naftalis & Frankel LLP

DOJ Criminal Division Releases Updated Guidance for Evaluation of Corporate Compliance Programs

On April 30, 2019, Brian A. Benczkowski, the assistant attorney general for the Criminal Division of the United States Department of Justice, announced the release of an updated version of the Criminal Division’s guidance for...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

Holland & Knight LLP

Recent Debarments Highlight Growing Risk of Sanctions By Multilateral Development Banks

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• Companies that operate globally face substantial risks associated with activities funded by multilateral development banks (MDBs). • Several recent debarment actions by the World Bank highlight those risks. • To...more

Thomas Fox - Compliance Evangelist

Using Strategic Risk to Your Advantage

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

The Volkov Law Group

What is the Real Risk of an FCPA Enforcement Action?

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When speaking to clients or potential clients, the question of risk of enforcement is the moose on the table. Sometimes, the question gets asked and other times, the subject is never discussed. To be fair, it is not an easy...more

Thomas Fox - Compliance Evangelist

LRN Compliance Program Effectiveness Report: Part III

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

Thomas Fox - Compliance Evangelist

LRN Compliance Program Effectiveness Report: Part II

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Holland & Knight LLP

Justice Department Reveals How It Evaluates Corporate Compliance Programs

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The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Thomas Fox - Compliance Evangelist

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part I

I guess Matt Kelly cannot leave his journalist roots for it was he who broke the story within the greater compliance community that the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of...more

The Volkov Law Group

Lessons Learned and Compliance Trends from the VW and Takata Scandals (Part III of III)

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When unraveling a major corporate scandal, especially multi-year schemes involving senior executives, the blame game or lessons learned approach can easily turn into a fruitless exercise. The VA and Takata scandals are...more

Thomas Fox - Compliance Evangelist

Tribute to Star Trek and Anti-Corruption Compliance Programs

September 8th is the 50th anniversary of the premier episode of the most iconic science fiction related television show during my lifetime – Star Trek. As most of you know, I am a self-confessed uber-trekkie and I can still...more

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