Anti-Corruption & Compliance Blog

As we look back on 2019, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2019:

• The Department of Justice (“DOJ”) brought 29 enforcement actions in 2019. 12 guilty pleas were entered and the DOJ obtained 4 convictions (Mark Lambert, Lawrence ...

Earlier this year, the U.S. Department of the Treasury issued a new “Framework for OFAC Compliance Commitments” (the “Framework”). The Office of Foreign Asset Control (“OFAC”) is the Treasury Department’s arm that administers and enforces economic and trade sanctions based on U.S. foreign ...

In our last alert, we discussed three tips to ensure an effective internal investigation: (1) develop and follow internal policies; (2) identify the audience that will evaluate and make decisions at the outset of the investigation; and (3) identify and understand the law that applies to the investigation ...

Whether big or small, internal investigations require companies to mobilize their resources efficiently and effectively. Internal investigations can be driven by external sources like the government or a lawsuit, while others are driven by internal sources like a whistleblower or the internal audit ...

With the first half of 2019 in the rearview mirror, it is a good opportunity to review the overall trends in Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) so businesses can better anticipate what ...

The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long investigation into the retail giant’s violations of the Foreign Corrupt Practices ...

As discussed in Part 1 and Part 2 of this series, the seven core principles of an effective integrity compliance program apply to businesses of any size, but there is no one-size-fits-all model to compliance. What is appropriate for a multi-national business with thousands of employees speaking numerous ...

In our last alert, we discussed the first three fundamental categories of an effective compliance program: (1) Risk Assessment; (2) Management Buy-in; and (3) Code of Conduct [see our previous alert for the full discussion  on these categories]. The next four are just as crucial:

These core principles are the ...

Never has the need for anti-corruption compliance programs for American companies been greater than it is today. This is not only for large multi-national companies, but for small to medium-sized businesses, particularly those doing business abroad and in high-risk countries.

The position of a compliance ...