Four federal agencies and state bank regulators said Tuesday that banks are no longer required to file suspicious activity reports for customers solely because they’re growing and cultivating hemp.… Continue Reading
Last week the Department of Justice reminded us that the FCPA remains a force to be reckoned with. And for the second time in as many years, I’ve taken to my keyboard to remind the world that, despite so many hopes and predictions, FCPA enforcement is not dead.… Continue Reading
Corruption can no longer be addressed as a legalistic or compliance issue by executives and directors. Nor is it enough to regard it as an ethical issue. Righteousness is not and will never be a guarantee for directors and executives.… Continue Reading
The White House yesterday released a national security paper defining U.S. interests and affirming the fight against corruption as a cornerstone of American foreign policy.
The White House sent a letter to Congress pledging a commitment to the “robust and thorough enforcement” of the Global Magnitsky Act.
Congress adopted the Global Magnitsky Act in December 2016.… Continue Reading
Attorney General Jeff Sessions said Monday that enforcing the Foreign Corrupt Practices Act is critical to protecting honest companies from competitors who choose to pay bribes.
Sessions, speaking at the Ethics and Compliance Initiative Annual Conference in Washington, DC, said corruption “increases the cost of doing business and hurts honest companies that don’t pay these bribes.”… Continue Reading
The SEC rule that would have required oil and gas and mining companies to disclose each year their payments to foreign governments was intended to increase transparency and prevent back-handers, bungs, and bribes from reaching those able to influence contractual decisions.… Continue Reading
A civil society group, Socio-Economic Rights and Accountability Project (SERAP), has sent an open letter to U.S. President Donald J. Trump urging his “Administration to attach and release to Nigeria some $500 million worth of U.S.-based… Continue Reading
The ethics & compliance community already knows we’re going to hear lots of chatter in coming months about easing the burden of compliance with the Foreign Corrupt Practices Act.
We’ll probably see a new attitude at the Justice Department, shifting away from prosecuting organizations in favor of prosecuting individuals.… Continue Reading
So the Trump Administration has nominated a new SEC chairman in the form of Jay Clayton, dealmaker and securities lawyer at Sullivan & Cromwell. The compliance community’s reaction seems to be vague concern, based on a paper (pdf) Clayton co-authored in 2011 criticizing FCPA enforcement.… Continue Reading
Much has already been written about the November election and FCPA enforcement and compliance. My perspective comes from a five-year experience cooperating with the DOJ, and which spanned two administrations, including a complete change of leadership at the Justice Department after President Obama’s first electoral victory.… Continue Reading