Mike Koehler takes a closer look at SEC’s commitment to holding individuals accountable for FCPA violations…
Given the nature and extent of the conduct at issue, as part of its plea agreement, Siemens was required to engage a corporate monitor for a three year period…
I think people need to realize that compliance due diligence under the FCPA can also be used to help companies do more than uncover potential FCPA issues but also help correctly assess the value of target companies.
One hypothetical noticeably missing from the FCPA guidance concerns the most important element of an FCPA anti-bribery violation – the “foreign official” element.
How serious can The World Bank’s sanctions process really be? After all, the Bank’s investigators lack many of the powers that national authorities often take for granted.
This post provides an overview of the Carson sentencing issues and highlights two issues from Judge Selna’s H. Carson sentencing memo.
Given the enforcement agencies’ untethered and boundless views on who is a “foreign official” under the FCPA, one never knows where a “foreign official” will pop up.
A recent survey established that at least 50 percent of companies have increased spending on anti-corruption compliance.
Many of Marshall’s qualities transcend the military and are useful when evaluating employees to become compliance practitioners or Chief Compliance Officers.
This article originally appeared on Professor Koehler’s FCPA Professor website (www.fcpaprofessor.com) and is reprinted with his permission. Since April the Department of Justice has been running a Kool-Aid stand and many people have been drinking the Kool-Aid. The Kool-Aid being served up and consumed is Morgan Stanley’s so-called declination. As noted in this prior post, in April in resolving an enforcement action [...]