On August 14, 2020, the U.S. Department of Justice (“DOJ”) issued Opinion Procedure Release 20-01, its first FCPA Opinion since 2014. The DOJ opinion states that, based on the facts and representations provided by the requesting party, a payment to a foreign state-owned investment bank for legitimate ...

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On July 16, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of apparent violations of the North Korea Sanctions Regulations by Essentra FZE Company Limited (Essentra), a global supplier of cigarette products located in the United Arab Emirates ...

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On June 1, 2020, the Department of Justice (DOJ) published an updated version of its guidance for “Evaluation of Corporate Compliance Programs,” originally published in February 2017. The guidance is intended to assist federal prosecutors, but it also shines light on how corporate compliance teams should be ...

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On May 7, 2020, the United States Supreme Court issued a decision in Kelly v. United States, reversing the convictions of Bridget Anne Kelly and William Baroni, two appointees of former New Jersey Governor Chris Christie, involved in the “Bridgegate” scandal. As Deputy Chief of Staff and Port Authority ...

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In November 2019, the U.S. Department of Justice (“DOJ”) issued revisions to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“Policy”). The Policy, which was first introduced in 2016, offers cooperation credit to companies in the form of a presumption of declination ...

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The COVID-19 pandemic national emergency has changed the way organizations are conducting business. As businesses adapt and begin to adjust to this new environment, it is important not to lose sight of the policies and procedures that guard your business from compliance risk. Below are a few areas to keep top of ...

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As we discussed in our December 2019 Compliance Alert, former Alston S.A. senior executive Lawrence Hoskins was convicted in November 2019 by a Connecticut jury on six counts of violating the Foreign Corrupt Practices Act (“FCPA”), three counts of money laundering, and two counts of conspiracy for his ...

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On January 13, 2020, Major League Baseball (MLB) announced the findings of an investigation into allegations that the Houston Astros had engaged in sign stealing during the 2017 and 2018 seasons. The investigation determined that the Astros used various methods (from center field cameras and video monitors ...

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

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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 ...

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