FCPA compliance


The Asia-Pacific Top 10 FCPA Enforcement Actions of 2014

FCPA enforcement has been on the rise of late, and several of the most significant enforcement actions taken in 2014 had connections to countries in the Asia-Pacific region. Wendy Wysong and her associates at Clifford Chance explore the largest and most impactful actions taken in the region this past year, with an analysis into the significance of each ...


Top FCPA Enforcement Trends To Expect in 2015

The future is often a mystery, but here and there we're given insight into what's coming. FCPA authorities have done just that for us over the past few months, speaking often about their intentions for investigations and enforcement actions ahead. So instead of just guessing at what the landscape will look like this year, we can just ...

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Byzantium and the Alstom FCPA Settlement – Part III

The final installment from Tom Fox in a series on the Alstom FCPA enforcement action, this post explores the accounting records violations the French parent company owned up to. As it happens, the charges are a bit puzzling, but it's made clear in the settlement not only that there were some serious misdeeds afoot, but that there were ...

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Germany in the World Cup and the Alstom FCPA Enforcement Action – Part II

The recent Alstom enforcement action has dwarfed many others, and for Tom Fox, it brings to mind last summer's soccer upset heard 'round the world - Germany trouncing Brazil in the World Cup. Today's piece delves into the deferred prosecution agreements, outlining the requirements they set for Alstom and what they mean for compliance practitioners in general.


Book-Ending FCPA Compliance: The Importance of Risk Assessments and Monitoring

Risk assessments and monitoring are essential to any successful compliance program, and as such, they're the two key components FCPA enforcement officials look for when evaluating a company's compliance efforts. If either piece is absent, there will be serious doubt as to the company's commitment to compliance and, of course, to its ability to prevent and address violations.

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The Alstom FCPA Enforcement Action – Part I

The first in a series of posts from Tom Fox on the recent Alstom enforcement action -- among the very largest of all FCPA actions to date both in terms of the scope of the investigation and the amount of fines levied against the offending party. Lessons to be learned from Alstom? The importance of controls cannot ...


What FCPA Enforcement was Thinking in 2014

FCPA enforcement agencies don't tend to keep their intentions secret. If you follow the investigations and enforcement actions, it's easy to discern where their focus lies and how companies can "buy" themselves some leniency. Officials at the DOJ and SEC have offered several insights into the agencies' thought processes for 2014. What do you think 2015 ...

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The Tangible and Intangible Drivers of FCPA Risk in Venezuela Today

Venezuela is considered by experts to be one of the most corrupt countries in Latin America, and the problem appears to have worsened over the years. The probability of FCPA violations is high for companies doing business in Venezuela, and when you look closely, it's easy to see why. Matteson Ellis explores the ways in which companies ...


Bobby Keys, the Rolling Stones and Establishing Trust

While due diligence is essential when doing business with or through third parties, ultimately trust is critical in maintaining successful business relationships. No matter how thorough the questionnaire or how in-depth the business justification, even well-vetted partners can do you wrong if the relationship consists of a series of box-ticking encounters. Don't overestimate the power of transparency.