ominous view of police officer in front of squad car

One of the World’s Most Feared Enforcement Tools

Posted by - July 5, 2018
The History of FCPA Enforcement, Part 2 In Part 1 of this two-part series on the history of the enforcement of the FCPA, Anne Eberhardt discussed some of the factors that led to its creation. In this second part, she describes how the FCPA evolved into one of the most…
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FCPA document with hands and gavel

How the Foreign Corrupt Practices Act Came to Be

Posted by - July 3, 2018
The History of FCPA Enforcement, Part 1 Anne Eberhardt, Senior Director at Gavin Solmonese and an expert in FCPA, forensic, compliance, fraud and corruption investigations, offers a brief history of the FCPA. In this first installment, she provides historical context for the regulation, discusses its 1977 enactment and touches on…
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Crash Landing: Lessons From the Panasonic FCPA Enforcement

Posted by - June 20, 2018
Those bemoaning the lack of Foreign Corrupt Practices Act (FCPA) enforcement activity can cease. With the Dun & Bradstreet Inc. (D&B) declination in April and May’s enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic), U.S. regulators at the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have…
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façade outside Odebrecht building in Sao Paulo

10 Lessons from Operation Car Wash

Posted by - April 3, 2018
The State of Corruption Risk in Latin America The biggest-ever corruption and bribery investigation in Latin America has seen scores of business leaders and politicians end up in prison. So riveting is the story that it’s now been dramatized into a series and streamed on Netflix. Andy Webb-Vidal explains the…
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TRACE International’s 2017 Global Enforcement Report

Posted by - March 15, 2018
TRACE International, the globally renowned anti-bribery standard setting organization, has published its annual Global Enforcement Report. The Global Enforcement Report (GER) provides graphic and textual analyses of all known investigations and enforcement actions involving transnational commercial bribery since the passage of the U.S. Foreign Corrupt Practices Act. The findings note a reversion to the…
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calculator and piggy bank

FCPA Investigations Without Breaking the Bank

Posted by - January 26, 2018
Costs can balloon quickly in FCPA investigations, however, these investigations don’t have to spin out of fiscal control. Corporate counsel can and should get to the root of alleged violations – certainly before the government does – without “boiling the ocean” to unearth the facts and decimating the organization’s bottom line. Based on Roscoe, Michael and Pat’s experience managing corporate investigations, both as defense counsel and as…
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Hong Kong

The Asia-Pacific Top 10 FCPA Enforcement Actions of 2017

Posted by - January 24, 2018
Asia Pacific continues to give rise to a large number of Foreign Corrupt Practices Act (FCPA) enforcement actions. Four of the nine companies that the US Department of Justice (DOJ) Fraud Section includes on its list of 2017 FCPA Enforcement Actions are based or were operating in the region, as…
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laptop money

Using Technology To Avoid FCPA Fines

Posted by - January 8, 2018
A new policy that has been enacted for enforcing the Foreign Corrupt Practices Act may significantly impact the way FCPA violations are handled within corporations. The more prompt these violations are handled, the better.
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illustration of Donald Trump gesturing in front of American flag

The Trump Effect on FCPA Enforcement

Posted by - October 24, 2017
As U.S. Enforcement Lags, International Attention to Domestic Corruption Takes a Front Seat Despite assurances from senior DOJ officials that the U.S. would maintain robust enforcement of the FCPA, enforcement has waned in the first eight months of the Trump presidency, with the DOJ and SEC combined announcing only four…
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