department of justice building sign with American flag behind

DOJ Expands FCPA Corporate Enforcement Policy

Posted by - August 30, 2018
The Implication for Non-FCPA Related Cases Michael Volkov discusses the Justice Department’s FCPA Corporate Enforcement Policy, enacted late last year; its efficacy so far; and its potential impact on corporate criminal cases unrelated to the FCPA. The Justice Department’s FCPA Corporate Enforcement Policy was announced in November 2017 with much…
handcuffs on a stack of Euros

AlixPartners Survey: Corruption Risk Around the World

Posted by - August 9, 2018
Corruption risk is alive and well in China and Latin America and growing in Russia, Africa and Middle East; international regulatory cooperation is making an impact NEW YORK (August 9, 2018) – AlixPartners, the global consulting firm, today released its 6th annual Global Anti-corruption survey which focuses on the challenges…
trends in yellow speech bubble

4 Current FCPA Enforcement Trends

Posted by - July 19, 2018
“Resources Reflect Policy” and Other Observations Michael Volkov discusses themes emerging in the DOJ’s and SEC’s enforcement of FCPA violations thus far in 2018. There are two distinct themes in FCPA enforcement: The first is consistency (i.e., that some enforcement actions are relatively consistent across the board), and, in the…
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…
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…

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…

How the Michael Cohen Investigation Defines and Highlights the Limits of the FCPA

Posted by - June 15, 2018
Political Ties This article will dig deep into the issue of whether President Trump’s lawyer, Michael Cohen, should be concerned about potential FCPA violations on the heels of revelations about payments received from multi-national corporations. It’s a complicated issue since the FCPA is very specific about limiting American influence on…
closeup of judge striking gavel

What Is the Current State of Anti-Bribery and Corruption Prosecution?

Posted by - March 23, 2018
Trump and the FCPA Instances of global corruption pepper our newspapers and news feeds. Closer to home, allegations of corruption have taken center stage in the American political landscape, and President Trump has been openly critical of the Foreign Corrupt Practices Act, leaving many in the compliance field to wonder…

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…

Miller & Chevalier’s FCPA Winter Review 2018

Posted by - March 7, 2018
Every quarter, Miller & Chevalier’s International practice publishes a review of the latest FCPA enforcement actions. This is a comprehensive guide to actions against corporations and individuals, ongoing policy developments and related litigation and international developments.  
concept of the world at war

Are We Winning the Battle Against Bribery and Corruption?

Posted by - February 8, 2018
with co-authors Paul Nash and Arturo del Castillo A Region-by-Region Analysis Organizations around the world are increasingly facing a diverse range of fraud-, cyber- and security-related challenges across a variety of sectors. The 10th edition of the Kroll Global Fraud & Risk Report (The Kroll Report) found that as compliance professionals…