Skip to main content
Insights
Inflation Reduction Act
Biden Administration Prioritizes Increased and Broadened Anti-Corruption Enforcement
On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity, global anti-poverty and development efforts, and democracy itself.” It directs...
DOJ Reveals Foreign Agent Cases Are Fara from Over
On March 6, Assistant Attorney General for National Security John C. Demers announced that the Department of Justice (“DOJ”) has designated a new deputy chief to lead the Foreign Agents Registration Act (“FARA”) unit and that DOJ will start treating...
DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations
On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy 1 that seeks to incentivize voluntary self-reporting by providing companies with more certainty regarding potential outcomes...
Anti-Corruption Enforcement in Mexico: Your Integrity Policy Matters
On July 19, 2017, Mexico’s General Law of Administrative Accountability will go into effect. It is the final part of a historic package of far-reaching anti-corruption laws, dubbed the National Anti-Corruption System, that were passed last year. Taken as a...
DOJ Releases New Guidance on Compliance Programs
On February 8, 2017, the Fraud Section of the Department of Justice (“DOJ”) quietly published pointed and specific guidance on how it assesses – and intends to assess – compliance programs in a report titled “Evaluation of Corporate Compliance Programs”...
DOJ Announces First Declinations After Implementing FCPA Pilot Program
The U.S. Department of Justice (DOJ) issued its first set of public declinations since its April unveiling of a new self-reporting Foreign Corrupt Practices Act (FCPA) pilot program. On June 7, 2016, Akamai Technologies, Inc., a Massachusetts-based internet services provider...
DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting
In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that encourages companies to voluntarily self-disclose FCPA-related misconduct in...
Improved U.S. - Cuba Relations Create Potential FCPA Risks for U.S. Companies Looking to Do Business There
The normalization of relations between the United States and Cuba offers potential lucrative business opportunities for companies that are prepared to meet Cuba’s unique corruption risks. On December 17, 2014, President Barack Obama and Cuban President Raul Castro announced the...
VimpelCom's Global FCPA Settlement - A Multinational Resolution
The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act (FCPA) resolution with VimpelCom, a Dutch telecommunications company...
Implementation Day: What Does It Mean for U.S. Companies Interested in Iran?
This Saturday, January 16, 2016, the International Atomic Energy Agency (IAEA) certified that Iran satisfied their obligations under their nuclear-related interim obligations under the Joint Comprehensive Plan of Action (JCPOA), also known as the Iran Deal. Upon that certification, Saturday...
SEC and Hitachi Reach FCPA Settlement Over Corrupt Payments in South Africa
The U.S. Securities and Exchange Commission (SEC) recently announced a settlement with Hitachi, Ltd. over allegations that the company sold shares in a South African subsidiary to a front company for the African National Congress (ANC), the ruling political party...
The Transparency Initiative: Are You Ready?
Introduction The UK is set to become the first EU member state to transpose the most recent EU directives on accounting and transparency rules in an effort to satisfy growing demands for a European-wide strategy to fight corruption in relation...
Salinas v. Texas: Your Silence May Be Used Against You
On June 17, 2013, the Supreme Court of the United States issued an opinion with important ramifications for anybody who may be interviewed in connection with a criminal investigation. In Salinas v. Texas , 570 U.S. ___ (2013) (Slip. Op...