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State-Owned Enterprises Foreign Corrupt Practices Act (FCPA)

Foley & Lardner LLP

What Every Multinational Company Should Know About … Anti-Corruption

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The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...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

Kohn, Kohn & Colapinto LLP

New Cop on a Bigger Block: The CFTC Steps into Enforcement of Anti-Corruption in Commodities Markets with Vitol Settlement.

The Commodity Exchange Act (CEA) tasks the Commodity Futures Trading Commission (CFTC) with regulating the U.S. derivatives markets. A December 3, 2020 , required it “to pay more than $95 million in civil monetary penalties...more

Orrick, Herrington & Sutcliffe LLP

For the First Time, the CFTC Uses its Powers to Combat Foreign Corruption

In a landmark action on December 3, 2020, the Commodity Futures Trading Commission (“CFTC”) announced resolution of its first enforcement action involving foreign corruption by issuing an order and settling charges against...more

Thomas Fox - Compliance Evangelist

J&F – The SEC Order

Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

J&F – The Bribery Schemes

Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

Farewell to Eddie Van Halen and Joint Venture Risks Under the FCPA

Eddie Van Halen died yesterday. He is the first rocker, more or less, of my generation to die after the age of 60. He was also one of the greatest guitarists ever. Indeed, I would rank him as the best guitarist of his...more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The Individual Guilty Pleas

We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more

Thomas Fox - Compliance Evangelist

Tribute to Gale Sayers and Criminal FCPA Plea by Sargeant Marine

Gale Sayers died Wednesday. For any serious student of the National Football League (NFL), Sayers will always be known as one of the greatest runners of all-time. His rookie season was one for the record books; scoring 22...more

A&O Shearman

DOJ Issues FCPA Opinion Procedure Approving Legitimate Payments To Government Instrumentalities

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On August 14, 2020, the U.S. Department of Justice (“DOJ”) released its first Foreign Corrupt Practices Act (“FCPA”) Opinion (the “August 14 Opinion”) in six years, in response to a request from a multinational company...more

Eversheds Sutherland (US) LLP

The DOJ issues its first FCPA advisory opinion after six years of silence

On August 14, 2020, the US Department of Justice (the DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years, which relayed that it did not intend to pursue an enforcement action...more

Thomas Fox - Compliance Evangelist

The Significance of Opinion Release 20-01

For the first time in six years, the Department of Justice (DOJ) has released an Opinion Release, denominated 20-01. At first blush it appears to be a straight-forward recitation of the equivalent of black letter law in the...more

Thomas Fox - Compliance Evangelist

Bribery Schemes from 2019 FCPA Enforcement Actions

In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 2 – Risk Assessment

I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more

Thomas Fox - Compliance Evangelist

Westport Fuel Systems – Control Fraud at Its Finest

Today, I conclude my short exploration of the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Each FCPA...more

The Volkov Law Group

Canadian Fuel Technology Company and Former CEO Settle SEC FCPA Case

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Westport Fuel Systems, a Canadian clean fuel technology company, and its former CEO, Nancy Gougarty, agreed to settle FCPA charges with the SEC for $4.1 million and $120k, respectively....more

Troutman Pepper

World Bank Debars Chinese Engineering Company for Fraudulent Bidding Practices in Connection With Liberian Infrastructure Project

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On June 12, 2019, the World Bank announced that China-based Dongfang Electronics Co. Ltd. (“Dongfang”) would be debarred for fifteen (15) months for fraudulently bidding on a $60 million electrical expansion project in...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

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• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - March 2018

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Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

BCLP

Foreign Corrupt Practices Act Enforcement: 2017 Year-in-Review

BCLP on

Enforcement of the Foreign Corrupt Practices Act (FCPA) again remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2017, resulting in 11 companies paying over $1.92 billion to...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part I

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more

Thomas Fox - Compliance Evangelist

The Ping FCPA Enforcement Action: Lessons for the Compliance Practitioner

The Securities and Exchange Commission (SEC) settled a Foreign Corrupt Practices Act (FCPA) enforcement action against an individual earlier this month when it announced the resolution of a matter involving Jun Ping Zhang,...more

Sheppard Mullin Richter & Hampton LLP

U.S. Targets Private Equity Funds for FCPA Scrutiny

The private equity industry is facing increased scrutiny by the U.S. Government for potential violations of the Foreign Corrupt Practices Act (“FCPA”). The Securities and Exchange Commission (“SEC”) has created a new private...more

The Volkov Law Group

Doing Business in China Should Be “Scary”

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Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for another posting on corruption risks in China. A little fear is healthy. It will keep you vigilant and aware. At this point if corporate...more

BakerHostetler

Foreign Corrupt Practices Act 2015 Update

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Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

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