Anti-Corruption & Compliance Blog

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 ...

In August 2021, the Securities and Exchange Commission (the “SEC”) announced multiple sizable whistleblower awards totaling approximately $16.1 million to 14 individuals. The awards ranged from $150,000 to $3.5 million. These recent awards continue a pattern by the SEC in late 2020 and 2021 of high dollar ...

On June 25, 2021, the Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”) simultaneously announced that the international engineering and project management firm, Amec Foster Wheeler (“Foster Wheeler” or the “Company”), a subsidiary of John Wood Group, plc, would ...

On June 3, 2021, President Biden issued a Memorandum on Establishing the Fight Against Corruption as a Core United States National Security Interest (the “Memo”). The Memo recognized the current Administration’s emphasis on curbing corruption domestically and abroad through strong governance and ...

On April 29, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), the agency that enforces and administers U.S. economic and trade sanctions, announced a settlement with Dallas-based  MoneyGram Payment Solutions, Inc. (“MoneyGram”) for violations of multiple U.S ...