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SEC Expected to Expedite FCPA Investigations in Light of Kokesh
On November 9, 2017, Steven R. Peikin, Co-Director of the SEC’s Division of Enforcement, delivered a keynote speech at a conference commemorating the 40th anniversary of the enactment of the Foreign...
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Expansion of FCPA “Pilot Program” is Good for Companies, but Heed the Fine Print
Deputy Attorney General Rod Rosenstein’s Nov. 29 announcement that the Department of Justice FCPA “Pilot Program” will be permanently expanded is good news for companies that repeatedly faced the...
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Unexplained Wealth Orders
Background For some time there has been a perception that the UK is a safe refuge for corrupt individuals seeking to conceal their unlawfully acquired assets. This has particularly been the case with...
View ArticleThe Perils of Global Expansion: World’s Largest Ad Agency Sanctioned $19...
Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange...
View ArticleDOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion
RELATED UPDATES: U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls (March 6, 2023) New Revelations in Ukraine Lead to Tightening Global Sanctions (April 8,...
View ArticleDOJ Publishes FCPA Declination on Cross-Border Bribery Investigation
Without fanfare, DOJ recently published a “declination and disgorgement letter,” the first FCPA declination published by the Department since August 2020. As disclosed in the letter, DOJ has declined...
View ArticleDOJ and SEC Kick Off the Second Quarter with Major FCPA Settlement with...
On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company...
View ArticleBrazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution
On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the...
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Cross-Border Enforcement and Trends — 2022 Year in Review
Key developments in U.S. cross-border enforcement were driven by the year’s most newsworthy developments, from Russia’s invasion of Ukraine and the battery of sanctions that swiftly followed, to the...
View ArticleEricsson Pleads Guilty, Agrees to Pay $206M in Fines, Following Alleged...
Last week, the U.S. Department of Justice (DOJ) announced that Sweden-based multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson) will plead guilty to breaching the...
View ArticleThe Foreign Extortion Prevention Act: Another Tool to Fight Foreign Corruption
In recent years, the Biden Administration has been vocal that combatting foreign public corruption is a key pillar of its national security efforts.[1] Consistent with those policy goals, on December...
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