Certain company processes might not constitute traditional notions of “internal controls,” but FCPA enforcement officials have taken the position that a wide range of activities is covered by the term.
Since the issuance of the DOJ’s and SEC’s FCPA Guidance in November 2012, FCPA legislative reform efforts have lost some steam.
As demonstrated below, the sentences handed down in 2013 were a mixed bag, and (except for Frederic Bourke) all individuals cooperated with the government to some extent.
Foreign Corrupt Practices Act (FCPA) enforcement activity in 2013 was robust, with the DOJ and SEC bringing 31 new FCPA enforcement actions, exceeding 2012’s total of 25.
Investment banks are increasingly concerned about corruption liability arising from issuers for which they structure and execute capital market transactions.
These days, more and more companies are developing internal resources to manage potential FCPA violations.
Under the FCPA, companies and individuals can be liable for the bribes that their agents, consultants, sales representatives, distributors, lawyers, accountants, brokers and other third-party intermediaries make ...
In the world of FCPA enforcement, 2013 was a big year. Some have pointed out, “After getting off to a slow start, with no official corporate FCPA settlements announced in the first quarter, 2013 witnessed two of the top 10 biggest settlements of all time.”
2013 was a significant year in FCPA enforcement. Both the Department of Justice and Securities and Exchange Commission continued to aggressively pursue FCPA cases and communicate their views on evolving best practices. In addition to the corporate enforcement actions, 2013 saw the greatest number of individual enforcement actions brought since the Gun Sting case. In this volume, you will read...
One of the most innovative features of Brazil’s new Anti-Bribery Law is Chapter 5, which establishes the possibility of leniency agreements for companies. This is a new concept in Brazil’s anti-corruption arena.
Surprisingly, the number of FCPA resolutions that actually involved the Asia-Pacific region sharply declined in 2013, against trend and in apparent contradiction of ubiquitous enforcement attention and coverage.
There has been considerable discussion over the last few years about anti-corruption developments in Brazil, Mexico, Argentina and Colombia. But what about the fifth OECD member state in the region – Chile?