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
What isn’t a Red Notice?
On June 9, 2025, Deputy Attorney General Todd Blanche announced that the U.S. Department of Justice (“DOJ” or the “Department”) will resume investigating and prosecuting violations of the U.S. Foreign Corrupt Practices Act...more
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
On June 9, 2025, the U.S. Department of Justice (“DOJ”) issued guidelines governing investigations and the enforcement of the Foreign Corrupt Practices Act (FCPA), following through on commitments made in President Trump’s...more
Since the President signed the February 10, 2025 Executive Order (Order) pausing enforcement of the Foreign Corrupt Practices Act (FCPA) (Client Alert: President Trump issues Executive Order “Pausing Foreign Corrupt Practices...more
U.S. Foreign Corrupt Practices Act (FCPA) enforcement activity may be at a temporary standstill, but that should not mean much for the day-to-day operations of global anti-corruption compliance programs. If the Department of...more
On February 10, 2025, President Trump issued an Executive Order entitled Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security. The executive order comes just days after the...more
Late on February 10, President Trump ordered Attorney General Pam Bondi to “pause” new Foreign Corrupt Practices Act (FCPA) enforcement for 180 days while the U.S. Department of Justice (DOJ) refocuses criminal enforcement of...more
On February 10, 2025, President Donald J. Trump signed an Executive Order pausing enforcement actions under the Foreign Corrupt Practices Act (FCPA), citing concerns that excessive enforcement was harming American businesses...more
On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks? Well,...more
We continue our exploration of corporate culture. Today, we consider the intersection of the Fraud Triangle and a toxic culture. The Fraud Triangle is well-known to most compliance practitioners. It is pressure, opportunity,...more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
The building blocks of any compliance program lay the foundations for a best practices compliance program. For instance, in the life cycle management of third parties, most compliance practitioners understand the need for a...more
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on a risk assessment, on an understanding of your...more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Compliance professionals are always looking for ways to collaborate and support internal business partners. Through the years, compliance professionals have devoted significant energy to building partnerships with the...more
We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues. It does not take a rocket scientist to...more
FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more
While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more
In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors. The year before, in 2019, DOJ insisted on the appointment of three independent corporate monitors – MTS...more
White collar practitioners Neil Smith, William Semins, Nicole Stockey, and David Peet discuss their key takeaways from this year’s 37th International Conference on the Foreign Corrupt Practices Act....more
The Coronavirus health crisis has wrought many changes in the business world and corporate compliance. Over the next few blog posts, I want to explore in some depth what I see are the key changes for the Chief Compliance...more
One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more