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White Collar Crimes

The Volkov Law Group

Episode 340: DOJ Updates Evaluation of Corporate Compliance Programs

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How prepared is your company to handle the evolving risks of artificial intelligence and other emerging technologies in its compliance program? In this episode of Corruption, Crime and Compliance, Michael Volkov delves into...more

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Post-Acquisition Integration and Investigation in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – September 2024

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What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...more

Vinson & Elkins LLP

Supreme Court Declines to Revisit Limitations on Anti-Kickback Statute: What This Means for Enforcement of Corruption, Kickbacks...

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On October 7, 2024, the U.S. Supreme Court declined to hear a case concerning the “willfulness” element of the Anti-Kickback Statute (the “AKS”). This decision leaves intact a recent Second Circuit holding, which established...more

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Pre-Acquisition Due Diligence in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Society of Corporate Compliance and Ethics...

Public-Private Partnerships to Stem Corruption

Governments don’t only want to prosecute companies for paying bribes. Increasingly, they are looking for companies to join with them to reduce the global challenge of corruption. To learn more we spoke with Shruti Shah,...more

DLA Piper

Federal Judge Rules Whistleblower Provision of the False Claims Act is Unconstitutional

DLA Piper on

In an eye-opening decision, a judge in the Middle District of Florida held that the unique whistleblower, or “qui tam,” provision of the federal False Claims Act (FCA) violates the Appointments Clause of Article II of the...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Enforcement Action: Performing a Root Cause Analysis to Inform Remediation

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Bradley Arant Boult Cummings LLP

Whistleblower Language in Separation Agreements Results in Large Settlements with SEC

On September 9, 2024, the Securities and Exchange Commission (SEC) announced settlements with seven public companies relating to their use of separation agreements that the SEC says violate whistleblower protection rules by...more

Womble Bond Dickinson

[Webinar] U.S. Anti-Corruption Enforcement in Latin America - October 22nd, 12:00 pm - 1:15 pm ET

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Latin America has been the focus of considerable attention by the Biden Administration and the DOJ. Despite strong ties based on trade, shared values and democratic traditions, Latin America is being tested with new and...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Enforcement Action: Lessons on Corrupt Payments

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Case: Lessons on Gifts, Travel and Entertainment

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

The Volkov Law Group

Episode 339: Four Sanctions Cases Everyone Should Know

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How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more

Thomas Fox - Compliance Evangelist

2024 ECCP-Embracing Continuous Improvement

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute, Principal Deputy Assistant Attorney General Nicole M. Argentieri discussed the Evaluation of Corporate...more

The Volkov Law Group

DOJ Updates Evaluation of Corporate Compliance Programs

The Volkov Law Group on

The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs.  As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more

DLA Piper

Company Liability in South Africa: Take Adequate Steps to Prevent Corruption or Face Criminal Prosecution

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An amendment to South Africa’s Prevention and Combating of Corrupt Activities Act (PRECCA) in April 2024 has created a new criminal offense relating to the failure by members of the private sector or state-owned entities...more

DLA Piper

EU-Wide Corporate Criminal Law: Tightening the Reins

DLA Piper on

The Council of the European Union recently submitted its proposal in the ongoing legislative process for a new directive to combat corruption in the EU. The new directive will allow the EU to impose worldwide...more

Mayer Brown

US DOJ Provides Details About Its Whistleblower Pilot Program in Practice and More US Attorneys’ Offices Launch Their Own Programs

Mayer Brown on

On September 17, 2024, senior officials from the US Department of Justice (DOJ) gave comments offering insight into its new Corporate Whistleblower Awards Pilot Program (“Pilot Program”) as it has operated in practice so far....more

Perkins Coie

Strike Force Cases Highlight Focus on National Security Priorities and Need for Strengthened Cybersecurity

Perkins Coie on

The U.S. Department of Justice (DOJ) announced criminal charges in five cases in connection with the Disruptive Technology Strike Force (Strike Force) on September 16, 2024. Launched in February 2023, the Strike Force is...more

DLA Piper

DOJ's Revised ECCP Signals Expectations of a Data-driven Compliance Program

DLA Piper on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced much-anticipated revisions to the US Department of Justice (DOJ)’s Evaluation of Corporate Compliance Programs (Revised ECCP)...more

The Volkov Law Group

Commerce Department Updated its Voluntary Self-Disclosure Policy for Export Controls Violations

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The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws.  Companies have to weigh carefully the risks when...more

Mayer Brown

DOJ’s Criminal Division Updates Policy on 3 Key Topics: Artificial Intelligence, Whistleblower Programs, and Compliance Program...

Mayer Brown on

On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri (PDAAG), speaking at the Society of Corporate Compliance and Ethics Annual Compliance & Ethics Institute, announced three key updates to...more

Wilson Sonsini Goodrich & Rosati

DOJ Raises Expectations on AI, Data Analytics, and More in New Guidance on Corporate Compliance

On September 23, 2024, the Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs policy (ECCP), which outlines the key factors prosecutors consider when evaluating the effectiveness of a...more

K&L Gates LLP

Anti-Bribery and Corruption Update

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Earlier this year, Australia enacted the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 (the Act) in an attempt to strengthen the country’s anti-bribery and corruption regime. The Act, which overhauls...more

Thomas Fox - Compliance Evangelist

The 2024 ECCP – Using Data Analytics to Determine Employee Engagement, Trust, and Corporate Culture

In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute. Principal Deputy Assistant Attorney General Nicole M. Argentieri spoke about the CWA and reviewed its early...more

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