Ten years ago, in April 2014, the DOJ announced the unsealing of a criminal indictment charging six individuals “with participating in an alleged international racketeering conspiracy involving bribes of state and central government officials in India to allow the mining of titanium
This recent post on the Global Anti-Corruption Blog hints that Canada may be “too nice” in enforcing its FCPA-like law (the Corruption of Foreign Public Officials Act).
The post states: “Canada’s track record of enforcing the CFPOA does not match
The following Covington attorneys contributed to this post: Steve Fagell, Nancy Kestenbaum, Aaron Lewis, Ashley Nyquist, Adam Studner, and Chas Hamilton.
On March 7, 2024, Deputy Attorney General (“DAG”) Lisa Monaco announced that DOJ is embarking on a “90-day sprint”
Do “many business leaders now appreciate that the FCPA offers them a measure of protection against foreign corruption.”?
This is a direct quote from the State Department’s recently released “National Action Plan on Responsible Business Conduct.” (See here).
There is
This recent Wall Street Journal article titled “DOJ Uncovering More Misconduct Through Self-Disclosure Program, Says Top Official” begins:
“More companies are choosing to voluntarily disclose misconduct to prosecutors after a policy revision last year that increased the potential benefits of doing so,
An industry sweep is a concept that entered the FCPA vocabulary over a decade ago.
As explained in this prior post by an FCPA practitioner:
“Industry sweeps are often led by the Securities and Exchange Commission (“SEC”), which has broad
This previous post covered the net $100.2 million FCPA enforcement action against Trafigura concerning conduct in Brazil.
This post highlights additional issues to consider.
Timeline
Trafigura was under FCPA scrutiny since at least early 2019 (see here from the prior
Since 2021, the DOJ has resolved 19 corporate Foreign Corrupt Practices Act enforcement actions.
The “Foreign” in Foreign Corrupt Practices Act refers to the location of the bribe recipient (as in “foreign” non-U.S. officials).
However, the “Foreign” in Foreign Corrupt
