How well positioned are today’s code-of-conduct practices to meet the effectiveness criteria for Corporate Compliance Programs embedded in the latest DOJ guidelines? That is, “Is the compliance program well designed? Is it being implemented effectively?… Continue Reading
Covington & Burling has translated into Chinese the DOJ’s April 2019 Guidance Document for the Evaluation of Corporate Compliance Programs.
Covington’s unofficial translation includes both English and Chinese.
In a series of key policy announcements between November 2017 and May 2018, the Department of Justice has demonstrated an increasingly coherent perspective on how it will handle key aspects of white collar criminal enforcement.… Continue Reading
Tomorrow is May 1st — also known as May Day or International Workers’ Day — a public holiday in most of the world, including our present location. It’s a day to honor workers and their achievements, and to give people a well-timed spring holiday.… Continue Reading
Michaela Ahlberg created a compliance program from scratch when she was hired in 2013 by Swedish telecommunications firm Telia following allegations of corruption in its foreign business dealings.… Continue Reading
The FCPA guidance that became part of the U.S. Attorneys’ Manual in November creates a presumption of declination if companies do four things — voluntarily self-disclose, fully cooperate, properly remediate, and disgorge their profits.… Continue Reading
2017 proved to be a blockbuster year for the FCPA and anti-bribery and corruption (ABC) enforcement at large.
From sustained record levels of enforcement (some 11 penalties levied, totaling $1.92 billion; the second largest year on record) to significant developments via the newly announced FCPA Corporate Enforcement Policy by the Department of Justice in late November, businesses are on notice that this remains a significant regulatory priority.… Continue Reading
Peru welcomed the new year by enacting into force Law 30424, which introduces corporate criminal liability applicable to bribery.
Peruvian law now recognizes the independent criminal liability of a legal person for local and foreign bribery, imposing sanctions ranging from fines, debarment from government contracting to dissolution of the legal entity.… Continue Reading
By almost any measure, the new FCPA enforcement policy is an important and positive development. Tom Fox, Bill Steinman, George Terwilliger, and others both here and beyond have noted as much, and I rise in concurrence.… Continue Reading