On January 28, 2021, Transparency International released its 2020 Corruption Perceptions Index (“CPI”). Transparency International is an organization focused on stopping global corruption and promoting transparency, accountability, and integrity. Its CPI scores are used by companies and individuals ...
MoreOn January 20, 2021, Joseph R. Biden, Jr. was inaugurated as the forty-sixth President of the United States. With the change in Presidential administration, we expect new priorities with regard to compliance and anti-corruption enforcement.
Department of Justice / FCPA Enforcement
President Biden has ...
MoreAs we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020:
- The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies entered into Deferred Prosecution Agreements, and the DOJ obtained 6 convictions ...
On October 22, 2020, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced the coordinated $2.9 billion resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action against The Goldman Sachs Group, Inc. (Goldman Sachs). The settlement is the largest in FCPA history ...
MoreEarlier this year, the U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Coast Guard issued a global advisory (the “Advisory”), providing information and tools to counter current and emerging trends of illicit shipping and sanctions ...
MoreOn 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 ...
MoreOn 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 ...
MoreOn 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 ...
MoreOn 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 ...
MoreIn 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 ...
MoreRecent Posts
- Transparency International’s 2020 Corruption Perceptions Index Indicates Corruption is Affecting COVID-19 Response
- Expected Enforcement Trends under the Biden Administration
- FCPA: 2020 Year-In-Review
- Goldman Sachs Reaches Record $2.9 Billion Settlement of Malaysia FCPA Violations
- Recent Advisory Opinion Provides Important Guidance to Mitigate Sanctions Risk
- DOJ Releases Rare FCPA Opinion Procedure
- Essentra Settlement Demonstrates Government Commitment to Compliance Framework
- DOJ Updates Corporate Compliance Evaluation Guidance
- Political Retribution in Bridgegate Cannot Sustain Federal Fraud Convictions in Kelly v. United States
- Key Considerations in the Timing of FCPA Violation Disclosures
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