Anti-Corruption & Compliance Blog

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 ...

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 ...

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 ...

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 ...

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 ...

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

• The Department of Justice (“DOJ”) brought 29 enforcement actions in 2019. 12 guilty pleas were entered and the DOJ obtained 4 convictions (Mark Lambert, Lawrence ...

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 ...

In our last alert, we discussed three tips to ensure an effective internal investigation: (1) develop and follow internal policies; (2) identify the audience that will evaluate and make decisions at the outset of the investigation; and (3) identify and understand the law that applies to the investigation ...

Whether big or small, internal investigations require companies to mobilize their resources efficiently and effectively. Internal investigations can be driven by external sources like the government or a lawsuit, while others are driven by internal sources like a whistleblower or the internal audit ...

With the first half of 2019 in the rearview mirror, it is a good opportunity to review the overall trends in Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) so businesses can better anticipate what ...