Anti-Corruption & Compliance Blog

On September 24, 2021, the Securities and Exchange Commission (“SEC”) announced a settlement with WPP plc, the world’s largest advertising group with dual headquarters in New York City and London. According to the SEC’s internal administrative order, WPP’s Indian subsidiary paid up to $1 million to ...

In August 2021, the Securities and Exchange Commission (the “SEC”) announced multiple sizable whistleblower awards totaling approximately $16.1 million to 14 individuals. The awards ranged from $150,000 to $3.5 million. These recent awards continue a pattern by the SEC in late 2020 and 2021 of high dollar ...

On June 25, 2021, the Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”) simultaneously announced that the international engineering and project management firm, Amec Foster Wheeler (“Foster Wheeler” or the “Company”), a subsidiary of John Wood Group, plc, would ...

On June 3, 2021, President Biden issued a Memorandum on Establishing the Fight Against Corruption as a Core United States National Security Interest (the “Memo”). The Memo recognized the current Administration’s emphasis on curbing corruption domestically and abroad through strong governance and ...

On April 29, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), the agency that enforces and administers U.S. economic and trade sanctions, announced a settlement with Dallas-based  MoneyGram Payment Solutions, Inc. (“MoneyGram”) for violations of multiple U.S ...

The U.S. Department of Labor recently announced that the Occupational Safety and Health Administration (“OSHA”) will oversee worker retaliation complaints under the Criminal Antitrust Anti-Retaliation Act (“CAARA”) and the Anti-Money Laundering Act (“ALMA”). Some employers may wonder why ...

The Commodity Futures Trading Commission (“CFTC”) recently announced the settlement of its first enforcement action involving foreign corruption. In December 2020, the CFTC issued a Consent Order, finding that Houston-based energy and commodities trading firm Vitol, Inc. defrauded counterparties ...

On January 28, 2021, Transparency International released its 2020 Corruption Perceptions Index (“CPI”).  Transparency International is an organization focused on stopping global corruption and promoting transparency, accountability, and integrity. Its CPI scores are used by companies and individuals ...

On January 20, 2021, Joseph R. Biden, Jr. was inaugurated as the forty-sixth President of the United States. With the change in Presidential administration, we expect new priorities with regard to compliance and anti-corruption enforcement.

Department of Justice / FCPA Enforcement

President Biden has ...

As we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020:

• The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies entered into Deferred Prosecution Agreements, and the DOJ obtained 6 convictions ...