One of the most significant developments in the ethics space in recent years is the recognition that “paper” programs don’t afford meaningful protection against misconduct or its consequences. Established companies such as Nissan and Pacific Gas & Electric and media companies reeling from #MeToo scandals generally have a compliance infrastructure of lawyers, Codes of Conduct, training and hotlines but nonetheless their CEOs and senior managers have behaved as if these safeguards didn’t apply to them.… Continue Reading
Four years on, the fallout from the 1MDB scandal continues. A key conspirator has agreed to forfeit up to $900 million in assets. Malaysian investigators just alleged that the country’s ex-premier approached prosecutors and foreign royalty about a cover up.… Continue Reading
In late 2007, while cooperating with one investigatory agency in London, I found out that another agency was also looking for me: Her Majesty’s Revenue and Customs (HMRC) had issued a border watch for me.… Continue Reading
Airbus SE paid $4 billion (€3.6 billion) to settle global bribery and trade charges with French, UK, and U.S. authorities Friday after an eight-year investigation triggered by a British whistleblower.… Continue Reading
Businesses are still failing to understand the corruption risks their organizations face and are still struggling to put the right anti-bribery and corruption (ABC) practices in place.… Continue Reading
As long as U.S. federal law enforcement priorities remain the same, licensed cannabis operators are unlikely to be prosecuted if they are completely compliant with state laws. However, if the DOJ or state regulators discover that a license was acquired through corrupt means, the license will not provide any protection.… Continue Reading
TechnipFMC plc paid the SEC $5 million Monday to settle FCPA offenses related to bribing Iraqi officials to win business with state-owned oil companies.
The London-headquartered oil and gas company disgorged $4.3… Continue Reading
The Criminal Division of the DOJ published expanded guidance on April 30 discussing the factors prosecutors should use to determine whether a company under investigation for misconduct will be regarded as having an effective compliance program.… Continue Reading
In December 2017, the DOJ first took aim at messaging apps in its FCPA Corporate Enforcement Policy, which required companies to prohibit employees from “using software that generates but does not appropriately retain business records or communications.”… Continue Reading
The DOJ said Tuesday that a Hawaii-based businessman admitted bribing officials from Micronesia.
CHS Inc. disclosed in an SEC filing Monday that it self-reported possible FCPA violations related to Mexican customs payments.
The Minnesota-based agriculture company said in a 10-K that it voluntarily disclosed the potential violations to the DOJ and SEC.… Continue Reading