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
Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more
Deja Vu all over again — Yogi Berra Yogi Berra said it best — we have seen this scenario before, with similar parties — corrupt foreign officials from Eskom (and Transnet), local partner requirements resulting in engagement...more
We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...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
Over the past 12 months or so there have been a series of Foreign Corrupt Practices Act (FCPA) enforcement actions where the respondents have changed and/or modified their sales models to get away from external third parties...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
The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious). The reasons for this may be a question of timing elements in the pipeline of cases....more
Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...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
Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more
We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses. Almost every FCPA enforcement action includes some form of third-party misconduct. The current...more
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...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
We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples....more
La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios. Exige que las empresas cuyos valores se...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It requires companies whose securities are listed in the US to maintain books and...more
Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive...more
Companies will often rely on a network of distributors to help sell their products in emerging markets. From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more
By using risk-based monitoring, you can begin to see things in “almost real-time, time-based trends of real data that you can then jump on and try to make adjustments before things get really wacky.” The implications to the...more
The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies. ...more
Microsoft’s bribery and controls violations reflect significant risks facing companies that rely on distributor and reseller networks to sell their products. Companies often enter and operate in emerging markets through...more