Insights on International Anti-Corruption & FCPA

This article provides an analysis of recent updates to federal corporate compliance guidance on artificial intelligence and other new technologies.

This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP).

Numerous regulatory jurisdictions internationally, as well as multiple nongovernmental organizations (NGOs) such as the World Bank, have increasingly used compulsory corporate monitorships as part of their respective resolution processes.

On March 7, at the annual American Bar Association (ABA) National Institute on White Collar Crime, US Deputy Attorney General (DAG) Lisa Monaco announced a new whistleblower program that will provide financial rewards to individuals who notify the US Department of Justice (DOJ) of misconduct.

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of the Foreign Corruption Practices Act (FCPA).

Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance.

On October 4, Deputy Attorney General Lisa O. Monaco addressed the Society of Corporate Compliance and Ethics and announced a new Department-wide Mergers & Acquisition (M&A) Safe Harbor policy.

The Criminal Division of the US Department of Justice (DOJ) and Enforcement Division of the US Securities and Exchange Commission (SEC) recently published its second edition of A Resource Guide to the US Foreign Corrupt Practices Act (the “Updated Guide”), which was originally released in November 2

Right before the holidays, President Trump and his Administration took significant steps toward using economic sanctions to tackle international human rights abuses and corruption.

On July 28, 2015, Mead Johnson Nutrition Company, an Illinois-based pediatric food producer, settled FCPA charges brought by the SEC for over $12 million.

Foreign Corrupt Practices Act (FCPA) violations can lead to significant collateral consequences.

In a closely watched case, the US Court of Appeals for the Eleventh Circuit has concluded that officers and employees of a foreign government-owned company may be “foreign officials” for purposes of the anti-bribery prohibitions of the Foreign Corrupt Practices Act (FCPA).