Using captive insurance alternatives to protect companies and their directors and officers for FCPA-related exposure
Daniel Chefitz and Sergio Oehninger
June 22, 2021
Increased regulatory enforcement exposure continues to present directors and officers (D&O) insurance challenges for corporate policyholders. Policies that cover the costly expenses incurred in connection with regulatory investigations, liability payments, and resulting securities litigation are becoming increasingly more difficult and expensive to obtain.… Continue Reading
What stands out on the FCPA Blog’s list of the ten biggest FCPA cases of all time?… 
We have seen a rapid increase in dedicated ethics and compliance departments and programs in Nordic companies during the last decade. However, there is no local regulation that explicitly requires formal ethics and compliance work.
In 2020, the DOJ and SEC brought FCPA enforcement actions against 12 companies and imposed financial penalties totaling a record $6.4 billion. For a comparison, in 2019, 14 companies paid a (then) record $2.9 billion to resolve FCPA cases.… 
Vitol Inc., the U.S. affiliate of Geneva-based Vitol group, entered into a deferred prosecution agreement with the Department of Justice Thursday to settle two charges that it conspired to violate the anti-bribery provisions of the FCPA by bribing officials in Brazil, Ecuador, and Mexico.… 
I recently conducted a virtual training session, during which I displayed a slide showing the top ten FCPA fines and penalties in history. A curious attendee asked whether my figures represent the DOJ and SEC’s gross penalties or the amounts that companies were actually obliged to pay to the U.S.
With Goldman Sachs’ $3.3 billion 
Chicago-based spirits maker Beam Suntory Inc. agreed Tuesday to pay the DOJ $19.6 million to resolve Foreign Corrupt Practices Act charges for improper payments by its Indian subsidiary.…