Libyan President Moammar Gadhafi at a state visit in 2008

Recent FCPA Cases: Lessons for Compliance Personnel

Posted by - October 17, 2018
Historic Corruption and Its Modern-Day Impacts Anne Eberhardt, CFE, CAMS and Senior Director at Gavin/Solmonese, discusses two notable cases involving corruption, bribery and consequent violations of the Foreign Corrupt Practices Act. Each offers instruction for compliance practitioners. This autumn we are commemorating two significant anniversaries: the 10-year anniversary of the…
exterior of Petrobras building

Petrobras Closes Out “Massive” Corruption Investigations and Litigation

Posted by - October 4, 2018
Resulting Settlements and Remedial Measures Brazilian oil and gas giant Petrobras has entered into a series of settlements in closing out corruption investigations and litigation. For a long period of time, corruption was endemic at the corporation (the DOJ estimates illegally generated funds for payments as at least $2 billion),…
man and woman shaking hands in office lobby

Very Pleased to Meet You: Market Rates for Introducers in Asia-Pacific

Posted by - September 25, 2018
Mitigating the Risk Posed by Introducers Wendy Wysong and associates at Clifford Chance write on the rise in prominence of “introducers” in Asia-Pacific countries and explain how the use of introducers can expose the organization to corruption risk. The team also discusses several recent cases that have resulted in fines…
projection of graphs displaying financial results

SEC Amends Definition of “Smaller Reporting Company”

Posted by - July 26, 2018
How the Changes Will Affect Financial Reporting Recent changes by the SEC to qualification thresholds have altered the qualifications for an organization to be considered a “smaller reporting company.” Penny Somer-Greif of Baker Donelson outlines the new requirements. The Securities and Exchange Commission (SEC) has adopted amendments to its rules…
cryptocurrency coins on blue digital background

Regulatory Oversight for Cryptocurrency?

Posted by - July 23, 2018
What Crypto Exchangers and Administrators Need to Know U.S. regulators have recently joined with an international coalition of tax enforcement authorities to investigate cryptocurrency-related crimes. Given that there’s been limited regulatory oversight of cryptocurrency in years past, where does this leave businesses whose bread and butter is cryptocurrency? Cryptocurrency markets…
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…

Whistleblower Laws: Current Issues

Posted by - July 18, 2018
Q&A with Rick Schroeder of Jones Walker Rick Schroeder, leader of the Corporate Compliance & White Collar Defense Practice at Jones Walker in New Orleans, discusses whistleblower laws and protections with CCI’s Publisher, Maurice Gilbert. Maurice Gilbert: What is the most important challenge for compliance officers relating to whistleblower laws,…
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…
elizabeth holmes of theranos

The Shoe Drops on Theranos’ Former CEO and COO

Posted by - June 20, 2018
Criminal Indictment Filed Charging Fraud The fallout continues for Elizabeth Holmes and Sunny Balwani, respectively the CEO and COO of Theranos. The pair were charged with fraud by the SEC and were indicted last week on wire fraud and conspiracy charges. Michael Volkov reviews the cautionary tale of Theranos, outlining…
red and white barrier on an empty road

Tips to Achieve Consolidated Audit Trail (CAT) Compliance

Posted by - April 23, 2018
How to Overcome Technological Roadblocks What a time to work in the GRC field: new technologies are constantly emerging to help companies meet their regulatory obligations. At the same time, many fragmented requirements have piled up over time. Chris Ekonomidis, Head of U.S. Business Consulting at Synechron, discusses the three…