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What began as good-natured tech tinkering last week ended down the rabbit hole of AI-powered content and its unsettling implications for compliance. And what a deep hole it is.… Continue Reading
What began as good-natured tech tinkering last week ended down the rabbit hole of AI-powered content and its unsettling implications for compliance. And what a deep hole it is.… Continue Reading
Stericycle, Inc. agreed Wednesday to pay the DOJ and SEC $80.7 million in penalties and disgorgement to resolve FCPA offenses in Argentina, Brazil, and Mexico.… Continue Reading
Formula One is an exciting spectacle. Unfathomable speed, exotic locations, and ultra-luxury brands make for a compelling fan experience without mentioning all the behind-the-scenes drama. F1 enthusiasts worldwide come together each race day to cheer on their drivers and teams.… Continue Reading
A former coal executive was arrested and charged Thursday with one count of conspiracy to violate the FCPA and two counts of violating the FCPA in connection with his alleged role to bribe officials at a state-owned Egyptian company.… Continue Reading
South Korea’s largest telecom company, KT Corporation, paid the SEC $6.3 million Thursday to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments to government officials in South Korea and Vietnam.… Continue Reading
Many an in-house compliance professional has spent a weekend (or ten) consumed with handling the tricky questions presented when an employee finds themselves incarcerated in one emerging market or another. It is unclear, especially at first, whether the arrest was justified in most cases.… Continue Reading
On January 21, the Department of Justice issued a new Opinion Procedure Release addressing a terrible situation – a company employee faces physical harm or duress in a foreign jurisdiction, and the only way to help them is to pay a bribe.… Continue Reading
Corruption is no longer the U.S. government’s persona non grata – reluctantly acknowledged and somewhat ignored outside FCPA enforcement. The President’s summer National Security Memorandum and recent U.S. Strategy on Countering Corruption place governmental and other anti-corruption activities front and center.… Continue Reading
In 2021, the DOJ and SEC brought FCPA enforcement actions against four companies and imposed financial penalties totaling $282 million. For comparison, in 2020, 12 companies paid a record $6.4 billion to resolve FCPA cases.… Continue Reading
The New York-headquartered biopharmaceutical giant paid the DOJ and SEC $60 million in 2012 to settle FCPA offenses in Bulgaria, Croatia, China, Czech Republic, Italy, Kazakhstan, Russia, Serbia, Indonesia, Pakistan, and Saudi Arabia.… Continue Reading
On Friday, November 26, 2021, the OECD adopted a new Recommendation with the potential to significantly enhance the global enforcement of bribery of foreign public officials in international business. While not legally binding, the OECD Working Group on Bribery will from now on monitor how different members implement the new Recommendation in the context of its country-by-country evaluation of the OECD Anti-Bribery Convention.… Continue Reading
Petrofac Ltd, a British oilfield services provider, agreed Monday to pay the UK Serious Fraud Office £77 million ($104.6 million) in penalties for Bribery Act offenses in Iraq, Saudi Arabia, and the United Arab Emirates.… Continue Reading