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White Collar Crimes

Burr Alert: Part III: White Collar Courier: Delivering News and Providing Guidance in White Collar Matters

by Burr & Forman on

In part one of this series, I detailed how the U.S. Department of Justice has focused its attention on the aggressive investigation and prosecution of “pill mill” cases. See “Part One: DOJ Devotes Resources, Vows to Come...more

The DOJ’s Revised FCPA Corporate Enforcement Policy: A New Blueprint for Corporate Cooperation and Credit

by Williams Mullen on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced the issuance of a revised FCPA Corporate Enforcement Policy (the “Policy”). Rosenstein announced that the “new policy enables the Department [of Justice]...more

Star Wars Week: Part IV – Episode VII – The Force Awakens and Disruption Innovation in Compliance

by Thomas Fox on

One of the key things the Department of Justice (DOJ) has communicated over the past few months is the importance of doing compliance rather than having a paper compliance program in place. In releasing the new Foreign...more

DOJ Incorporates FCPA Pilot Program into U.S. Attorneys' Manual Providing Permanent Incentives for Strong FCPA Compliance

by Blank Rome LLP on

Action Item: The U.S. Department of Justice (“DOJ”) recently included the principles of its Foreign Corrupt Practices Act (“FCPA”) Pilot Program into the U.S. Attorneys’ Manual (“USAM”), and reinforced its message to...more

Star Wars Week: Part III – Return of the Jedi – A good final result

by Thomas Fox on

While I am not sure how much celebrating HSBC might be doing this week, they should have pride in making it through the five-year DPA. The bank worked very hard to overcome its miss-steps and hopefully it will continue to do...more

Star Wars Week: Part II – The Empire Strikes Back – Due Diligence

by Thomas Fox on

I break due diligence down into three stages: Level I, Level II and Level III. Candice Tal, Founder and Chief Executive Officer (CEO) of Infortal Worldwide, in an article entitled “Deep Level Due Diligence: What You Need to...more

The Best Defense Is A Good Offense: FCPA Corporate Enforcement Policy Cements Importance Of Compliance Programs

The Department’s revised FCPA Corporate Enforcement Policy—which will be incorporated into the United States Attorneys’ Manual—builds on and makes permanent the Department’s 2016 FCPA Pilot Program....more

Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations

by Michael Volkov on

The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?...more

Star Wars Week: Part I – What is Risk?

by Thomas Fox on

Whether you utilize one approach or another, analyzing the results of your risk assessment is as important as doing the risk assessment. With the recent Department of Justice (DOJ) remarks around how they will review the...more

What Multinational Companies in Argentina Need to Know About Anti-Corruption Now

by Kobre & Kim on

Underscored by the recent contentious presidential and congressional elections, during which corruption was — as it is throughout the region — a hot-button issue, anti-corruption enforcement in Argentina is on the rise....more

The DOJ’s Latest Compliance Program Warning

U.S Deputy Attorney General Rod Rosenstein recently announced the Department of Justice’s revised FCPA Corporate Enforcement Policy. The revised Policy is based on the DOJ’s FCPA Pilot Program (in place since April 2016),...more

Global Legal Insights: Bribery & Corruption, 2018 - China

by Latham & Watkins LLP on

China has had strong anti-corruption laws for many years. On 1 January 1980, the Criminal Law of the People’s Republic of China (the “PRC Criminal Law”), containing the criminal offences of bribery and corruption, came into...more

Global Legal Insights: Bribery & Corruption, 2018 - Japan

by Latham & Watkins LLP on

Japan is widely perceived to be one of the least corrupt countries in the world. Transparency International ranked Japan as the 20th least corrupt country out of 176 in the most recent Corruption Perceptions Index. The World...more

Significant Reform Signalled for Australia's Foreign Bribery Regime

by Jones Day on

On 6 December 2017, the Commonwealth Government announced its intention to significantly reform Australia's existing anti-foreign bribery regime. The Crimes Legislation Amendment (Combatting Corporate Crime) Bill 2017, now...more

New Revenue Recognition Standard – The Podcast Series

by Thomas Fox on

In May 2014, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606) for public business entities, certain not-for-profit entities, and...more

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

by Michael Volkov on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

by Bracewell LLP on

On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

White-Collar Motive, Gun Crazy Movie

In 1950, producers Frank and Maurice King released Gun Crazy, a sometimes surreal Bonnie-and-Clyde story with an introverted, pacifist gun lover (Barton Tare, played by John Dall) and an English femme fatale sharpshooter...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The UK and EU made a significant breakthrough early this morning to “unlock” Brexit divorce negotiations. The still-rough agreement would see Britain repaying $53 billion and addressed in at least vague terms thorny issues...more

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

by Thomas Fox on

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

The World In U.S. Courts - Fall 2017

FSIA Does Not Exempt US Bank from Subpoena for Production of Records of Accounts Maintained by Central Bank of Nigeria - The World in U.S. Courts: Fall 2017 - Foreign Sovereign Immunity Act (FSIA)/Political Question Doctrine....more

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

by K&L Gates LLP on

At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more

DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

The Foreign Corrupt Practices Act of 1977 (FCPA) makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. On November 29,...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The latest on the potential Disney move for “significant parts of 21st Century Fox,” which is nearing completion and could see Murdoch scion leaving his father and brother in order to work for Big Mouse....more

New FCPA Enforcement Policy Ends the Compliance Defense Debate

by Thomas Fox on

As I continue my exploration of the new Department of Justice (DOJ) policy regarding Foreign Corrupt Practices Act (FCPA) enforcement, the FCPA Corporate Enforcement Policy (Policy), one of the things that struck me was the...more

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