Anti-Corruption & Compliance Blog

The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long investigation into the retail giant’s violations of the Foreign Corrupt Practices ...

As discussed in Part 1 and Part 2 of this series, the seven core principles of an effective integrity compliance program apply to businesses of any size, but there is no one-size-fits-all model to compliance. What is appropriate for a multi-national business with thousands of employees speaking numerous ...

In our last alert, we discussed the first three fundamental categories of an effective compliance program: (1) Risk Assessment; (2) Management Buy-in; and (3) Code of Conduct [see our previous alert for the full discussion  on these categories]. The next four are just as crucial:

These core principles are the ...

Never has the need for anti-corruption compliance programs for American companies been greater than it is today. This is not only for large multi-national companies, but for small to medium-sized businesses, particularly those doing business abroad and in high-risk countries.

The position of a compliance ...

The Department of Justice (“DOJ”) recently announced that it is declining to prosecute Cognizant Technology Solutions Corporation (“Cognizant”) for paying bribes to government officials in India in violation of the Foreign Corrupt Practices Act (“FCPA”). In its declination letter, the DOJ ...

On January 28, 2019, President Donald Trump issued an Executive Order including Petroleos de Venezuela, S.A. (PdVSA), Venezuela’s state-owned oil company, and any entity owned or controlled by PdVSA, within the definition of the term “Government of Venezuela.” The definition was also broadened to ...

As we kick off a new year, businesses should take the time to review their anti-corruption and compliance programs and make sure they are up-to-date and adaptable to the continuously changing environment. Here are five trending areas to keep an eye on in 2019:

1. USMCA (NAFTA II) Anti-Corruption Provisions
   On November ...