Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Encouraging and Managing Employee Self-Reporting
The Latest on Antitrust Compliance
Andy Dunbar and Nick Morgan on What the SEC Expects from Your Internal Investigation
Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
FERC: A Discussion on its Mission, Market Manipulation Investigations, and Common Violations
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
FCPA Compliance and Ethics Report-Episode 380, Laura Perkins on issues around self-disclosure
Nonpayment of Subcontractors: Can Subcontractors Get Any Help From the Government?
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Corporate Criminal Liability – Interview with Bridget Rohde, Member, Mintz Levin
On 24 April 2025, the UK’s Serious Fraud Office (“SFO”) launched new guidance for corporates on self-reporting, cooperation and deferred prosecution agreements (“DPAs”). Among other things, the new guidance states that, if a...more
In our client alert, “The Case for Compliance: Why UK and EU Businesses Should Continue to Invest in Their Compliance Programs”, we highlighted seven reasons why, despite the US’ pause on bribery enforcement under the Foreign...more
U.S. Attorney General (AG) Pam Bondi on her first day in office – Feb. 5, 2025 – sent several memos to all employees of the U.S. Department of Justice (DOJ) laying out top priorities. In one memo, the DOJ instructs its...more
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
Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more
In yet another indication that the Biden administration is continuing to ramp up white collar enforcement, the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on April 20, 2022 that...more
The Serious Fraud Office (“SFO”) has recently updated its Operational Handbook to include a chapter on DPAs (the "Updated Handbook"). For companies under investigation, the question of whether or not to cooperate with the...more
A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded. For too...more
Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more
On 16 July 2019, three individuals were acquitted of conspiracy to corrupt and conspiracy to bribe. On the basis of the same evidence, their employer, Sarclad Limited, had previously admitted corporate criminal liability and...more
We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more
The CFTC announced an Enforcement Advisory on self-reporting and cooperation for violations of the Commodity Exchange Act, or CEA, involving foreign corrupt practices. ...more
Brief Comments on The Director of the Serious Fraud Office v. Eurasian Natural Resources Corporation Limited [2018] EWCA Civ 2006 - On Sept. 5, 2018, the Court of Appeal of England and Wales handed down a unanimous...more
The recent conviction of UK company Skansen Interiors Limited (SIL), for the corporate offence of failure to prevent bribery has caused controversy. This is the first conviction under S7 of the Bribery Act after a contested...more
In an important decision given on February 21, 2018, a jury in English court proceedings has considered for the first time what “adequate procedures” should be for the purpose of a defense to the corporate offense of failing...more
The Australian government agencies responsible for investigating and prosecuting foreign bribery have released joint best practice guidelines that indicate how they will approach self-reporting by companies voluntarily...more
On 6 December 2017, Australia's Federal Government tabled the Crimes Legislation Amendment (Combatting Corporate Crime) Bill 2017 ("Bill"), which contains various amendments to Australia's foreign bribery regime, including...more
The world of science fiction can be exhilarating. If you ever read The Foundation Trilogy or Martian Chronicles, you know what I mean. The concept of parallel universes has always been an intriguing idea where believers can...more
On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...more
The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more
A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more
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
Let’s start with a big “If.” I know that sounds like a real turn off but bear with me. Assuming that the Justice Department is ready to turn over a new approach to criminal enforcement and aggressively prosecute culpable...more
Just to add to the cacophony of voices campaigning during this primary season, DOJ, SEC, FINRA, and CFTC officials launched their own campaign promoting recent initiatives to increase corporate self-reporting of potential...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more