Anti-Corruption & Compliance Blog

While companies increase focus on external risks by enhancing regulatory compliance, anti-corruption policies, and cybersecurity, they must not lose sight of internal risks, including internal fraud and embezzlement. The Association of Fraud Examiners reports that organizations lose an average of 5% of ...

In previous posts on the Porter Hedges Anti-Corruption & Compliance Blog, our team has discussed the U.S. Securities and Exchange Commission’s (“SEC”) proposal to amend its rules and require disclosures related to cybersecurity practices. The SEC wants to enhance and standardize the disclosures ...

Cybersecurity is the goliath of tech-related concerns for companies of all sizes, not just large corporations. The Cybersecurity & Infrastructure Security Agency (“CISA”) encourages small and midsize businesses to focus on their risk management policies and procedures to mitigate risks associated with ...

According to the Cybersecurity & Infrastructure Security Agency, cybersecurity is the process whereby information and communications systems, and the information contained in those systems, are protected from and/or defended against damage, unauthorized use or modification, or exploitation. As noted by ...

On March 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to its rules to require additional disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies. These new proposed rules expand on over a decade of focus by ...

In late January 2022, the Department of Justice (“DOJ”) issued Opinion Procedure Release 22-01, its first Foreign Corrupt Practices Act (“FCPA”) Opinion since 2020. The opinion states that based on the specific facts presented by the party requesting the opinion (the “Requestor”), a $175,000 ...

In response to Russia’s anticipated and then executed invasion of Ukraine, last week the U.S. Department of Treasury ("Treasury") announced two new rounds of economic sanctions against Russian-connected financial institutions and individuals.

On February 22, 2022, the Treasury announced sanctions ...

As we look back on 2021, several anti-corruption enforcement trends emerge. The following summarizes the key developments of the prior year and trends to watch in 2022:

• The Department of Justice (“DOJ”) brought 24 enforcement actions in 2021. Only three were against companies: Deutsche Bank, Amec Foster ...

On October 19, 2021, the U.S. Securities and Exchange Commission (“SEC”) announced that Credit Suisse Group AG (Credit Suisse) agreed to pay $100 million to the SEC (among other penalties to other agencies) for violations of the Foreign Corrupt Practices Act’s (“FCPA”) internal controls and books and ...

On September 24, 2021, the Securities and Exchange Commission (“SEC”) announced a settlement with WPP plc, the world’s largest advertising group with dual headquarters in New York City and London. According to the SEC’s internal administrative order, WPP’s Indian subsidiary paid up to $1 million to ...