Who are today’s corporate criminal defendants?
The lull in FCPA enforcement has greatly reduced the number of companies entering into pre-trial agreements, either deferred or non-prosecution agreements, plea agreements, or declinations with...
View ArticleDOJ publishes new Opinion Procedure Release on stipends for foreign officials
The Department of Justice published a new Opinion Procedure Release (23-02) related to a training events and logistical support company meeting a U.S. government task order as part of a contract that...
View ArticleIs private equity bad for compliance?
According to some, we should fear private equity because it operates in secret and is therefore more dangerous to society than public money. Does the argument hold water when it comes to FCPA...
View ArticleHow to wreck an organization from the inside
During World War Two, the Office of Strategic Services or OSS (which later became the Central Intelligence Agency) published a secret document called the Simple Sabotage Field Manual. It came with a...
View ArticleWhat is driving compliance underground?
Start with this: There were 8,000 public companies listed on U.S. exchanges 25 years ago, and now there are fewer than 4,000. Then ask: Who or what is to blame? Commentators usually blame private...
View ArticleBiotech company receives declination with disgorgement for Mexico bribes
Lifecore Biomedical, Inc., formerly known as Landec Corporation, received a declination with disgorgement Friday from the DOJ for FCPA violations in Mexico. According to the Declination Letter, the DOJ...
View ArticleBasel AML Index: Risks are rising across the board
The release on November 13 of the 12th Basel AML Index ranking of money laundering and terrorist financing risks in 152 jurisdictions takes a look at why risks are rising and what to make of the...
View ArticleTwo UK reinsurance brokers settle FCPA violations with the DOJ
Two British reinsurance brokers settled FCPA violations with the DOJ on Monday for bribes paid to officials at Ecuadorian state-owned insurance companies. Tysers Insurance Brokers Limited, a subsidiary...
View ArticleUK enacts powerful new legislation to tackle fraud epidemic
The newly enacted UK Economic Crime and Corporate Transparency Act (ECCTA) has introduced several new criminal offenses that are aimed directly at corporate and individual fraud, even introducing a new...
View ArticleSanctions don’t work. That’s why we’ll see more of them
If sanctions did what they were supposed to, they’d hit their targets hard, produce intended results, and come to an end. But that’s not happening. Instead, sanctions — now several dozens of them — are...
View ArticleWhat can compliance learn from industrial failures?
I recently had the opportunity to tour three manufacturing facilities in Europe — for aircraft, pharmaceuticals, and watches. While those might seem to have little in common, I found one strong common...
View ArticleWorld Bank debars civil engineering company and managing director
The World Bank debarred a Botswana-based civil engineering company and its managing director Wednesday for fraudulent practices connected to projects in Zambia and Tanzania. Multi-Tech Consult (PTY)...
View ArticleMake onboarding a ‘golden time’ for compliance
Onboarding is a small window when recruits are excited, impressionable, and optimistic. What better time to show them what’s required and expected, why it’s important, and what happens if they fall...
View ArticleSwiss prosecutor charges Trafigura, says ‘disorganization’ led to foreign...
Federal prosecutors in Switzerland charged a unit of commodity trading powerhouse Trafigura with bribing an Angolan official connected to the oil and gas industry. The charges cite Trafigura’s...
View ArticleHow did Nasdaq violate OFAC’s Iran sanctions?
The Treasury Department’s Office of Foreign Assets Control announced a resolution with New York-based stock exchange operator Nasdaq Friday for violations of sanctions against Iran. Nasdaq agreed to...
View Article‘New Rule: Follow up everything three times’
Harry’s post about Nasdaq’s violations of the Iran sanctions recites very odd facts. Nasdaq seemingly did everything right to comply. And yet, this “large and commercially sophisticated international...
View ArticleConnecticut trading company pays $98.5 million to resolve FCPA investigation
The DOJ said Thursday that Freepoint Commodities LLC, a trading company based in Stamford, Connecticut, will pay $98.5 million to resolve violations of the Foreign Corrupt Practices Act stemming from a...
View ArticleNow Streaming: Transparency induced angst
Last week, Netflix released streaming data for the first time covering over 18,000 titles in its catalog and nearly 100 billion hours viewed. But for me, this transparency report was accompanied by an...
View ArticleWhy is there more corporate hypocrisy than ever?
Hypocrisy is saying one thing but doing another. It’s the gap between words and action, and we’re all guilty of it sometimes. But I’ve been wondering about corporate hypocrisy. There’s more now, and...
View ArticleMerry Christmas from the FCPA Blog
From the FCPA Blog, we wish you a Merry Christmas and hope your homes are filled with warmth, love, and peace. Here’s one of our favorite traditional Christmas songs that will be on repeat this...
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