Understanding the DOJ's Recent Corporate Enforcement Policy Changes
FCPA Compliance Report: Recent DOJ Policy Announcements
An Ounce of Prevention Podcast | The International Anti-Corruption Prosecutorial Taskforce and the Future of Global Enforcement
Everything Compliance: Episode 154, The Law Firms in Trouble Edition
SBR-Author’s Podcast: The Unseen Life of an Undercover Agent: A Conversation with Charlie Spillers
Compliance into the Weeds: Leaving on a (Qatari) Jet Plane
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
The JustPod: A murder-for-hire allegation, public corruption trial, and notable acquittal
Work This Way: A Labor & Employment Law Podcast | Episode 43: How Employers Can Navigate White Collar Crime with Erica Barnes & Christian Dysart of Maynard Nexsen
Daily Compliance News: April 15, 2025, The Redefining Corruption Edition
Criminal Health Care Fraud Enforcement: Projections for 2025 and Beyond – Diagnosing Health Care Video Podcast
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
An Ounce of Prevention Podcast | Preparing for the UK Failure to Prevent Fraud Offence
Sunday Book Review: March 23, 2025, The Hard-Boiled Edition
Jones Day Talks®: Corporate Fraud Investigations in 2025: Lessons, Trends, and Need-to-Knows
Episode 359 -- Review of the EU Whistleblowing Directive with Alex Cotoia and Daniela Melendez
The Presumption of Innocence Podcast: Episode 56 - A Strategic Gamble: The Risks, Costs and Rewards of Going to Trial
What’s the difference between a Red Corner Notice and a Red Notice?
False Claims Act Insights - Some FCA Whistles Are Louder Than Others
RICO's Person/Enterprise Distinction - RICO Report Podcast
This essay traces the origin and development of the first dedicated law school course on corporate compliance and ethics programs in the United States. Responding to legal and practice developments over the last two decades,...more
The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more
We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more
A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more
I have long been interested in business leadership. I approached a good friend Richard Lummis to ask if he would host me in such a series. Out of this came 12 O’Clock High, a Podcast on Business Leadership....more
The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more
The decision to bring a lawsuit on behalf of a corporation is entrusted to the corporation’s board of directors. A shareholder may not maintain a derivative lawsuit on behalf of a corporation without first making a demand on...more
I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more
In a shareholder derivative action, to survive a motion to dismiss for failure to plead facts showing demand futility, a derivative plaintiff must plead particularized facts showing either actual involvement by a majority of...more
Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigor when it comes to an...more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more
Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more
In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying...more
Welcome to my second installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series and today I want to explore and, indeed, honor the second in the series but what many viewers...more
Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more
In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more
I did not think it would be possible that another Houston professional sports team could under-perform the sad-sack Houston Astros in 2013, who ended the season with a winning percentage of .313%. However the Houston Texans...more