FCPA Compliance Report - James Koukios on the Monaco Speech
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
Nota Bene Episode 29: The Essential Elements of Effective Corporate Compliance Programs with Jim McGinnis
Day 13 of One Month to Better Investigations and Reporting-The Yates Memo and Internal Investigations
Day 9 of One Month to Better Reporting and Investigations-The Investigation Team
Day 8 of One Month to Better Investigations and Reporting Day 8-Preparing for the Investigation
Everything Compliance-Episode 11, the first 100 Days of the Trump Administration, Part II
FCPA Compliance Report-Episode 319-Brandon Essig on Prosecutor's View of the Yates Memo
Internal Investigations: The Impact of the Yates Memo, the FCPA Unit Pilot Program and Recent Legal Decisions
This Week in FCPA-Episode 1
Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more
By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more
On February 8, 2017, the U.S. Department of Justice (DOJ) released a list of important topics and sample questions that the Criminal Division’s Fraud Section has frequently found relevant in evaluating the adequacy of a...more
Last April, the Criminal Division of the U.S. Department of Justice launched a one-year pilot program in the Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit. The pilot program, self-described as “building” on the...more
Donald Trump has gone on the record as saying the Foreign Corrupt Practices Act (FCPA) is a “horrible law and it should be changed” and that it puts US businesses at a “huge disadvantage.” This statement was made in the...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
Welcome to my third installment in this month’s classic monster movie festival. This year I am revisiting the Frankenstein series. Today I want to explore the final movie where Boris Karloff starred as Frankenstein’s Monster;...more
The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more
On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...more
The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more
The Department of Justice (DOJ) recently initiated a one-year pilot program to encourage companies to self-report violations of the Foreign Corrupt Practices Act (FCPA). Any company contemplating self-reporting such a...more
Companies face an ever-changing constellation of risks, enforcement priorities and demands for internal controls and compliance program elements. As more resources are poured into government enforcement programs, companies...more
Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
In April, the Department of Justice (DOJ) announced a one-year pilot program offering certain violators of the Foreign Corrupt Practices Act (FCPA) the possibility of reduced sanctions on top of any credit provided for by the...more
We had an interesting week of anti-corruption enforcement actions last week, both in the US and the UK. We have now had four Foreign Corrupt Practices Act (FCPA) enforcement actions since the announcement of the Depart Of...more
Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more
In April, the Fraud Section of the United States Department of Justice announced several measures designed to enhance its effort to discover and prosecute violations of the Foreign Corrupt Practices Act (FCPA). See, 15 U.S.C....more
For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more
Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more
More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more
The U.S. Department of Justice (“DOJ”) released a memorandum (the “FCPA Enforcement Memorandum”) on April 5, 2016 detailing a new enforcement plan for Foreign Corrupt Practices Act (“FCPA”) investigations. The DOJ announced...more
The U.S. Department of Justice (DOJ) recently announced a one-year enforcement pilot program intended to encourage companies to voluntarily self-report misconduct under the Foreign Corrupt Practices Act (FCPA). Building on...more
The Department of Justice (DOJ) on April 5 announced a new, one-year pilot program for companies to self-report Foreign Corrupt Practices Act (FCPA) violations. The announcement comes amid other increased FCPA enforcement...more
On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more