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Third-Party Department of Justice (DOJ) Bribery

Ankura

Internal Control Lessons Learned from Global Anti-Corruption Enforcement in 2024

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2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more

The Volkov Law Group

Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls...

The Volkov Law Group on

A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a number of significant indicators of a...more

Porter Hedges LLP

Lack Of Sufficient Third-Party Diligence And Oversight Leads To $41 Million Penalty For Foster Wheeler

Porter Hedges LLP on

On June 25, 2021, the Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”) simultaneously announced that the international engineering and project management firm, Amec Foster Wheeler (“Foster Wheeler”...more

Lowenstein Sandler LLP

1st FCPA Case Under Biden Offers Compliance Reminders

Lowenstein Sandler LLP on

The first Foreign Corrupt Practices Act case under President Joe Biden's administration reinforces some well-known risks for companies subject to the FCPA — namely, increased U.S. and international enforcement and cooperation...more

Thomas Fox - Compliance Evangelist

The Ahsani’s Information – The Fraudulently Obtained Certifications

This week I am mining the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, for what they might mean for Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

The Panalpina Settlement Day Record May Finally Be Broken: The Unaoil Execs Guilty Pleas

Nine years ago today, 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. It was...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on

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

The Volkov Law Group

DOJ and SEC Raising the Stakes on Third Party Risk Management

The Volkov Law Group on

If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....more

McDermott Will & Emery

Focus on China - October 2015

McDermott Will & Emery on

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Thomas Fox - Compliance Evangelist

Great Structures Week V – The Tacoma Narrow Bridge Failure and Preventing Failure in Your Compliance Program

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

NAVEX

A Prescriptive Guide To Third Party Risk Management

NAVEX on

The recent examples of compliance program credits for Morgan Stanley and Ralph Lauren have demonstrated that, more than ever, an effective compliance program can protect a company from criminal indictment and generate bottom...more

NAVEX

Lessons from Ralph Lauren: Designing Better Ways to Manage Third Party Risk

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Trying to avoid the unusually strict import controls in Argentina and facilitate faster clearance of its products through customs, a subsidiary of Ralph Lauren Corp. was found to have bribed local officials between 2005 and...more

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