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Securities and Exchange Commission (SEC) Non-Prosecution Agreements

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Paul Hastings LLP

DOJ Criminal Division Announces New Voluntary Self-Disclosure Pilot Program for Individuals

Paul Hastings LLP on

On April 22, 2024, the Acting Assistant Attorney General for the Department of Justice (“DOJ”) Criminal Division (“Acting AAG”) Nicole M. Argentieri offered commentary in a blog post regarding the Criminal Division’s newest...more

Society of Corporate Compliance and Ethics...

Understanding the Whistleblower Pilot Program in the Southern District of New York

In January 2024 the US Attorney’s Office for the Southern District of New York (SDNY) set a shockwave through the business world by announcing a new whistleblower pilot program. To understand what the policy says and what it...more

Paul Hastings LLP

More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends

Paul Hastings LLP on

On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more

Holland & Knight LLP

Cooperation with SEC: Yielding More Benefits, but Lack of Predictability Remains

Holland & Knight LLP on

Although the SEC has long adhered to its Seaboard Report of Investigation to outline the analytical framework for the agency's cooperation program for companies, the exact benefits of self-policing, self-reporting,...more

The Volkov Law Group

Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements

The Volkov Law Group on

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

The Volkov Law Group

Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements

The Volkov Law Group on

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2023

Morrison & Foerster LLP on

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

Womble Bond Dickinson

Better Late Than Never: A Voluntary Self Disclosure Case Study

Womble Bond Dickinson on

As previously reported, the Department of Justice (DOJ) has announced comprehensive corporate criminal enforcement policy changes utilizing both “carrots” and “sticks” to encourage companies to voluntarily self-disclose...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 3 – The Comeback

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 2 – How to Hire Corrupt Agents

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 1 – Background

Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

The Volkov Law Group on

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

HaystackID

Cooperation Standards in Government Investigations: Practical Tips

HaystackID on

Editor’s Note: From time to time, ComplexDiscovery highlights publicly available or privately purchasable announcements, content updates, and research from cyber, data, and legal discovery providers, research organizations,...more

American Conference Institute (ACI)

[Event] 11th Summit on Anti-Corruption Brazil - May 25th - 26th, São Paulo - State of São Paulo, Brazil

Brazil’s Anti-Corruption and Compliance Community Will Gather for Large, 1:1 and Smaller-Group Discussion! As the longest-standing anti-corruption and compliance gathering in Brazil, Summit on Anti-Corruption Brazil is...more

Lowenstein Sandler LLP

Best Practices To Ensure DPA Compliance After Ericsson

Lowenstein Sandler LLP on

On Oct. 21, Ericsson Inc. disclosed that the U.S. Department of Justice asserted that the company had "breached its obligations" under a 2019 deferred prosecution agreement "by failing to provide certain documents and factual...more

Foley & Lardner LLP

Review of Recent Whistleblower Developments - April 2021

Foley & Lardner LLP on

Whistleblower Developments is a periodic report covering significant cases, decisions, proposals, and legislation related to whistleblower statutes and how they may impact your business. Recent developments include: SEC...more

ArentFox Schiff

Beyond Robinhood: SEC Oversight in the FinTech Industry

ArentFox Schiff on

With SEC claims on the rise and the recent Whistleblower amendments, FinTech businesses will be well-served by reviewing their compliance operations and consulting with counsel as needed to mitigate avoidable risk. Is...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For September 2020

Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Kilpatrick

Ending the Decade on a High: U.S. Government’s 2019 FCPA Enforcement Highlights

Kilpatrick on

The U.S. Government’s 2019 FCPA enforcement efforts led to new milestones; further cooperation with international authorities; and continued use of independent corporate monitors.  The following are key takeaways of these...more

Faegre Drinker Biddle & Reath LLP

3 FCPA Compliance Lessons From Microsoft's Settlement

Microsoft’s recent settlement with the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) over violations of the Foreign Corrupt Practices Act (FCPA) sheds light on the DOJ’s new Corporate Enforcement...more

A&O Shearman

Technology Company Resolves DOJ And SEC FCPA Allegations, With Hungary Subsidiary Entering Three-Year, Monitor-Free NPA

A&O Shearman on

On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 5: Ringo and The End – Microsoft FCPA Settlement – Part 4

Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 4: In-A-Gadda-Da-Vida – Microsoft FCPA Settlement – Part 3

Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more

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