Anti-Corruption & Compliance Blog

The U.S. Department of Labor recently announced that the Occupational Safety and Health Administration (“OSHA”) will oversee worker retaliation complaints under the Criminal Antitrust Anti-Retaliation Act (“CAARA”) and the Anti-Money Laundering Act (“ALMA”). Some employers may wonder why ...

The Commodity Futures Trading Commission (“CFTC”) recently announced the settlement of its first enforcement action involving foreign corruption. In December 2020, the CFTC issued a Consent Order, finding that Houston-based energy and commodities trading firm Vitol, Inc. defrauded counterparties ...

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 ...

On 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 ...

As 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 ...

Earlier 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 ...

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 ...

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 ...

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 ...