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Enforcement

Enforcement Trends
Enforcement Actions

Nov. 13, 2019

In New Guidance, SFO Outlines Internal Investigation Expectations

Oct. 30, 2019

How Companies Can Respond to the Boom in FCPA Enforcement Fueled by International Cooperation

Oct. 30, 2019

New DOJ Guidance Offers a Gentler Standard on Inability-to-Pay Claims

Oct. 16, 2019

In New Guidance, SFO Indicates It Wants Companies to Waive Privilege

Oct. 2, 2019

Understanding and Mitigating Sub-Party Risk

Oct. 2, 2019

DOJ’s Miner Talks Individuals, Big Data and More Guidance to Come

Sep. 18, 2019

SFO Guidance Moves Toward Transparency but Offers No Guarantees

Sep. 4, 2019

Five Considerations in Cross-Border Anti-Corruption Matters

Aug. 7, 2019

Lessons in Self-Reporting and Cooperation From the Walmart Settlement

Aug. 7, 2019

DOJ’s 2019 Enforcement Activities Demonstrate a Continued Commitment to FCPA Enforcement

Jul. 24, 2019

Analyzing Walmart’s Unique Monitorship and Its Compliance Failures and Fixes

Jul. 10, 2019

Revisiting the China Initiative: Will the Focus on FCPA Prosecutions of Chinese Companies Produce Results?

Jul. 10, 2019

A Side-by-Side Look at How Walmart’s Monitor Agreement Compares to Previous Monitor Agreements

Jul. 10, 2019

Walmart Finally Settles for $282M and a Monitor

Jun. 12, 2019

Why International Companies Are Integrating the ECCP Into Their Compliance Programs

Jun. 12, 2019

Conducting Internal Investigations in the Shadow of U.S. v. Connolly

May 29, 2019

CFTC’s Director of Enforcement Explains Decision to Regulate Foreign Corruption

May 29, 2019

A Close Look at the New ECCP’s Commentary on Compliance

May 15, 2019

Convictions, Clarity and Compliance: The Continued Evolution of Canadian Bribery Enforcement

May 15, 2019

A Side-by-Side Look at How the Revised ECCP Compares to the Original

May 15, 2019

Analyzing the DOJ’s New Evaluation of Corporate Compliance Programs

May 1, 2019

Practical Implications of the CFTC’s Enforcement Advisory on Foreign Corrupt Practices

May 1, 2019

The Pipe Is Always Full: FCPA Enforcement Officials Predict Business As Usual

Apr. 03, 2019

How AFA Compliance Program Controls Are Changing the French Anti-Corruption Compliance Landscape

Apr. 03, 2019

Examining Transparency International’s 24th Annual Corruption Perception Index: Key Critiques and Takeaways

Apr. 03, 2019

Updates to the Corporate Enforcement Policy Attempt to Address Company Concerns

Mar. 20, 2019

DOJ’s Rosenstein and Benczkowski Discuss Individual Accountability, Transparency, Proportionality and the Corporate Enforcement Policy

Mar. 20, 2019

The Developing Anti-Corruption Battle Between the United States and China

Feb. 20, 2019

Recent DOJ Alum Sandra Moser Discusses Maximizing Cooperation Credit

Feb. 20, 2019

Quick Look at Recent DOJ Policy Changes

Feb. 6, 2019

When Is an Individual “Substantially” Involved in a Crime?

Jan. 23, 2019

DOJ’s Precarious Plan to Trade Its Compliance Counsel for Internal Training and Expertise

Jan. 23, 2019

Changes to Justice Manual on Individual Prosecutions Moderate but Preserve the Yates Memo

Jan. 9, 2019

FCPA Prosecutions and the C-Suite

Jan. 9, 2019

The DOJ’s “New” Monitor Policy: Carefully Selected Monitors, Thoughtfully Scoped Monitorships

Jan. 9, 2019

Recent Developments in Latin American Anti-Corruption Enforcement

Jan. 9, 2019

Corruption Enforcers Discuss Benefits and Pitfalls of Increasing International Cooperation

Dec. 12, 2018

The DOJ’s “New” Monitor Policy: An Announcement of the Obvious

Dec. 12, 2018

The DOJ’s FCPA Corporate Enforcement Policy One Year Later

Dec. 12, 2018

DOJ’s Focus on Compliance Expands Beyond the FCPA, Cronan Says

Nov. 28, 2018

What Does a “Bigger and Stronger” SFO Mean for Companies?

Nov. 14, 2018

Government and Defense Attorneys Discuss Hot-Button SEC Issues

Oct. 31, 2018

Will the FCPA Be Used to Prosecute Domestic Bribery Cases?

Aug. 8, 2018

Government Enforcers From Argentina, Brazil and the U.S. Discuss Recent Victories

Aug. 8, 2018

Miner’s First Speech As a Criminal Division Leader Focuses on M&A

Jul. 25, 2018

As the U.K. Bribery Act Turns Seven, Experts Take Its Pulse

Jul. 11, 2018

What SocGen and Legg Mason Say About French and American Enforcement

Jul. 11, 2018

Piling On? Examining the Reality of Multi-Jurisdictional FCPA Resolutions

Jun. 27, 2018

SocGen Reaches Historic Deal With France and U.S., Legg Mason Tags Along

Jun. 27, 2018

Anti-Corruption Enforcement Continues to Increase Around the World

Jun. 13, 2018

Anti-Corruption Enforcement Continues Apace Under New Administration

May 30, 2018

Joint Head of Bribery at the SFO Discusses the Agency’s Priorities

May 30, 2018

Making Sense of the DOJ’s New Statements on Disappearing Messaging Apps

May 16, 2018

An Insider’s Take on France’s New Approach to Foreign Corruption

May 16, 2018

How Significant Is the DOJ’s New Directive on Coordination?

May 16, 2018

Deciphering De-Conflictions: An Interview With WilmerHale’s Kimberly Parker

May 2, 2018

SEC and DOJ Officials Predict That Current FCPA Enforcement Trends Will Continue, Defense Attorneys Agree

Apr. 18, 2018

DOJ Steers the Compliance Conversation Toward Culture

Apr. 18, 2018

ACR Program Examines FCPA Enforcement and Local Anti-Corruption Efforts in China and Singapore

Apr. 18, 2018

The History and Reach of dd-3 Jurisdiction and Lessons for Companies Investigating Potential Violations

Apr. 4, 2018

Any Decrease in FCPA Enforcement Under Trump Will Be Overshadowed by International Enforcement, Experts Predict

Feb. 7, 2018

Analyzing 2017 SEC Enforcement Activities and Their 2018 Implications

Jan. 24, 2018

SEC Signals Aggressive Stance on Individual Responsibility, Including Potential CCO Liability, in FY 2017 Annual Report

Jan. 24, 2018

Lessons Learned From the First-Ever French Convention Judiciaire d’Intérêt Public Concluded With HSBC

Dec. 13, 2017

Rosenstein Announces New FCPA Corporate Enforcement Policy and Promises Ongoing Enforcement

Dec. 13, 2017

Top FCPA Officials Discuss How International Cooperation and Individual Prosecutions Are Reshaping Anti-Corruption Enforcement, the Defense Bar Responds

Nov. 15, 2017

Broken Windows, Admissions and Stale Conduct: The State of Enforcement at the SEC

Nov. 15, 2017

From FCPA Prosecutor to Company Protector: An Insiders’ View on the Current Climate

Nov. 1, 2017

Stars of the FCPA Bar Discuss Recent Enforcement Developments

Oct. 18, 2017

Are U.K. Enforcement Authorities Sending the Wrong Message to Companies?

Oct. 4, 2017

Massive Telia Settlement Indicates International Cooperation Will Continue Under New Administration

Sep. 20, 2017

Significant Sentences May Signal Continuing Commitment to Individual FCPA Enforcement

Sep. 20, 2017

Top SEC Officials Put Mr. and Ms. 401K at the Forefront but Say No Big Changes to Enforcement to Come

Aug. 16, 2017

How the SEC May Circumvent the Five-Year Statute of Limitations on Disgorgement Under Kokesh v. SEC

Aug. 2, 2017

Former SEC and DOJ Attorneys Discuss Thorny FCPA Questions on Jurisdiction and Liability

Jun. 21, 2017

Channeling the Channel-Partner Risk: Addressing Anti-Corruption Risk with Channel Partners in the Technology Sector

Jun. 21, 2017

SEC Enforcement After Kokesh

Jun. 7, 2017

SEC and DOJ Address Corporate Concerns About Future FCPA Enforcement

May 24, 2017

A Rare Jury Conviction for a Bribe-Taker Proves the Worth of FBI Foreign Corruption Units

May 24, 2017

Regional Risk Spotlight: Rafael Jimenez-Gusi Discusses Corruption Perceptions and Compliance Expectations in Spain

May 24, 2017

Current and Former FCPA Officials Debate Enforcement Trends and Strategies

Apr. 26, 2017

DOJ Seeks to Reassure on FCPA Enforcement

Mar. 1, 2017

2016 Brought Heavy Enforcement, a Flurry of Settlements and Disruption to the FCPA Space

Feb. 1, 2017

A New Era in FCPA Disclosure

Jan. 18, 2017

Jay Holtmeier of WilmerHale Discusses What’s to Come After a Blockbuster Year of FCPA Enforcement

Dec. 21, 2016

Government and Defense Bar Perspectives on the New Weapons in the FCPA Arsenal

Dec. 7, 2016

Ceresney and Yates Continue to Stress Individual Accountability, Voluntary Reporting and Cooperation

Nov. 9, 2016

DOJ and SEC Continue to Stress the “Holy Trinity” of Self-Disclosure, Cooperation and Remediation

Jun. 1, 2016

SEC’s Brockmeyer, DOJ’s Kahn Discuss Recent FCPA Enforcement Trends

Jun. 1, 2016

Current and Former Agents Discuss the Five Pillars of the FBI’s FCPA Strategy

May 18, 2016

Earning Cooperation Credit Under the Fraud Section’s FCPA Pilot Program (Part Three of Three)

May 18, 2016

Yates on the Yates Memo

May 4, 2016

How Will the Fraud Section’s Pilot Program Change Voluntary Self-Reporting? (Part Two of Three)

May 4, 2016

Effective FCPA Compliance Strategies in the Wake of the Panama Papers

May 4, 2016

Employee Interviews in Internal Investigations After Yates: A Conversation With Quinn Emanuel and EY

Jan. 27, 2016

Former Prosecutor Nat Edmonds Discusses the Implications of the Recent Changes to the U.S. Attorneys’ Manual (Part Two of Two)

Jan. 13, 2016

Former Prosecutor Nat Edmonds Discusses the Implications of the Recent Changes to the U.S. Attorneys’ Manual (Part One of Two)

Jan. 13, 2016

Examining New DOJ Compliance Counsel Hui Chen’s Four Elements of a Successful Compliance Program

Dec. 16, 2015

Brockmeyer and Stokes Offer Four Benefits of Cooperation and Four Ways Companies Can Go Wrong in Their Internal Investigations

Dec. 2, 2015

Top FCPA Enforcers Discuss Evolving and Diverging Enforcement Approaches and the Defense Bar Responds

Dec. 2, 2015

How the Expanding Petrobras Scandal May Spark a New Era of Multi-Lateral Enforcement

Dec. 2, 2015

Ceresney and Caldwell Remarks Highlight New SEC Self-Reporting Policy, Cooperation, Remediation and Transparency

Nov. 18, 2015

The SEC’s Kara Brockmeyer Answers Hot-Button Enforcement Questions

Nov. 18, 2015

DOJ Compliance Counsel Hui Chen Is on the Job and Looking for Key Aspects of Strong Compliance Programs

Nov. 18, 2015

U.S. Attorneys’ Manual Changes Announced by Yates Push Companies to Provide More Information About Individuals

Nov. 4, 2015

Former DOJ Prosecutors Weigh In on Self-Reporting, Individual Prosecutions, International Cooperation and Enforcement Tactics

Oct. 21, 2015

A Defense Lawyer, a Prosecutor and a Witness Discuss Cooperating with the Government

Oct. 7, 2015

How Will the Yates Memo Change DOJ Enforcement? (Part Two of Two)

Sep. 23, 2015

How Will the Yates Memo Change DOJ Enforcement? (Part One of Two)

Aug. 19, 2015

Mayer Brown Attorneys Discuss Global Corruption Risk in the Financial Services Industry

Aug. 19, 2015

James Tillen of Miller & Chevalier Talks 2015 Enforcement Trends and Predictions

Aug. 5, 2015

DOJ’s New FCPA Compliance Counsel: A Fairer Assessment for Companies

Aug. 5, 2015

Four Compliance Lessons from Lesser-Known FCPA Cases

Jul. 22, 2015

Mitigating Corruption Risk in the Middle East (Part One of Two)

Jul. 8, 2015

Government Officials and Defense Bar Offer Insights on FCPA Enforcement, Voluntary Disclosure and Cooperation

Jun. 24, 2015

FCPA Enforcement Officials and Defense Bar Advise on Anti-Corruption Compliance Policies

Jun. 10, 2015

FCPA Enforcement Officials and Defense Bar Debate FCPA Policy

May 27, 2015

Prosecutors and Defense Lawyers Discuss FCPA Risk Areas, Government Expectations and the Length of Investigations

Apr. 29, 2015

Top FCPA Officials Discuss Government Tactics and Lessons from Enforcement Actions

Mar. 18, 2015

Ceresney, Focusing on Pharma, Discusses SEC Enforcement Priorities and Compliance Expectations

Feb. 18, 2015

Private Equity FCPA Enforcement: High Risk or Hype?

Feb. 18, 2015

Identifying and Addressing FCPA Exposure for Lenders

Jan. 21, 2015

Preparing for the Increasing Role of Whistleblowers in FCPA Enforcement

Jan. 21, 2015

FCPA Corporate Settlements of 2014: Details, Trends and Compliance Takeaways

Dec. 17, 2014

Top FCPA Officials Talk Compliance Tips and the Defense Bar Weighs In

Dec. 17, 2014

Key Compliance Takeaways from the OECD Foreign Bribery Report

Dec. 3, 2014

Top FCPA Enforcers Tout Voluntary Disclosure and Warn About International Cooperation; The Defense Bar Responds

Dec. 3, 2014

Caldwell and Ceresney Push Companies on FCPA Compliance, Cooperation and Self-Reporting

Dec. 3, 2014

OECD Launches “New Weapon” in Global Push to Fight Corruption

Nov. 19, 2014

Finding Synergies in OFAC and FCPA Compliance

Sep. 10, 2014

Mitigating Bribery Risks Using Financial Controls, Risk Assessments and Leveraging Internal Resources

Sep. 10, 2014

Analyzing and Addressing Corruption Risks in Southeast Asia

Jul. 9, 2014

Davis Polk FCPA Experts Assess Global Anti-Corruption Trends (Part Two of Two)

Jun. 25, 2014

Davis Polk FCPA Experts Assess Global Anti-Corruption Trends (Part One of Two)

Jun. 11, 2014

FCPA Compliance Strategies for Hedge Funds and Private Equity Firms

Jun. 11, 2014

Doing Business in India: Avoiding Corruption Risks and Monitoring Compliance Programs

May 28, 2014

Corruption Considerations for Private Fund Managers: An Interview with Molo Lamken Partner Justin Shur

May 14, 2014

Compliance Leaders from Citigroup and Morgan Stanley Examine FCPA Risks and Solutions for Financial Institutions

May 14, 2014

Global Enforcement Developments Evaluated by FCPA Experts

May 14, 2014

Global Enforcement Developments Evaluated by FCPA Experts

Apr. 30, 2014

Deputy Attorney General James Cole Discusses the Hallmarks of Successful Compliance Programs and Individual Prosecutions

Apr. 30, 2014

FCPA Experts in the Public and Private Sector Share Seven Lessons from Recent Cases (Part Two of Two)

Apr. 16, 2014

FCPA Experts in the Public and Private Sector Share Seven Lessons from Recent Cases (Part One of Two)

Apr. 16, 2014

Former Special Inspector General for Iraq Reconstruction Discusses Middle East Anti-Corruption Compliance Strategies

Apr. 2, 2014

Top DOJ and SEC Officials Discuss FCPA Enforcement Priorities and Mechanics

Apr. 2, 2014

In Final Speech as Criminal Division Head, Mythili Raman Emphasizes DOJ’s Focus on Anti-Corruption Efforts, Highlighting Individual Convictions and Foreign Cooperation

Mar. 19, 2014

Corruption Risks and Compliance Programs in the Oil & Gas Industry: An Interview with Samuel Cooper of Paul Hastings LLP

Mar. 19, 2014

Eye-Opening Report Helps Companies Tackle European Corruption Risks

Feb. 19, 2014

A Synthesis of Top Firms’ FCPA 2013 Year in Review Insights

Feb. 19, 2014

Six Things Every Business Lawyer Needs to Know About the FCPA

Feb. 19, 2014

Corruption Risk and the Changing Legal Climate in Latin America

Jan. 22, 2014

Assessing the Year in FCPA Enforcement and Looking Ahead

Jan. 8, 2014

A Perspective from the FCPA Defense Bar on Brockmeyer and Duross’ “Year In Review”: Interview with Danforth Newcomb, of Shearman & Sterling

Dec. 18, 2013

What Private Fund Managers Must Know About FCPA Enforcement

Dec. 18, 2013

Charles Duross and Kara Brockmeyer Discuss What Matters to Regulators When Negotiating FCPA Settlements (Part Two of Two)

Dec. 18, 2013

FCPA Corporate Settlements of 2013: Details, Trends and Compliance Takeaways

Dec. 4, 2013

Charles Duross and Kara Brockmeyer Discuss Five FCPA Enforcement Trends That Matter to Regulators: Individual Prosecutions, Administrative Proceedings, Global Coordination, Corporate Monitors and Third Parties (Part One of Two)

Dec. 4, 2013

Four Ways the SEC Enforcement Landscape Is Changing and Why They Matter to FCPA Practitioners

Nov. 20, 2013

The Changing Dynamics of Anti-Corruption Enforcement in Brazil

Nov. 6, 2013

The Anti-Corruption Report, Berkeley Research Group and Paul Hastings to Present Webinar on the Impact of Recent Initiatives on SEC Enforcement

Nov. 6, 2013

DOJ FCPA Unit’s John Buretta and Shearman & Sterling’s Dan Newcomb Offer Public and Private Perspectives on Key FCPA Challenges

Nov. 6, 2013

Five Lessons from 2013 FCPA Enforcement: Transaction Monitoring, International Cooperation, Documenting Hiring Decisions, Risk Assessments and Individual Prosecutions

Oct. 23, 2013

Why the Direct Access Partners Case Matters for Financial Sector Anti-Corruption Compliance

Oct. 23, 2013

K&L Gates Panel Reviews Anti-Corruption Enforcement in the U.S., the U.K., China, Australia, Latin America, Africa, Southeast Asia and Russia

Oct. 23, 2013

How the New Brazilian Anti-Corruption Law Impacts U.S. Corporations

Sep. 26, 2013

Transparency International Report Finds That Poor Legislative Oversight of Defense Spending Increases Corruption Risk

Aug. 7, 2013

How Can Financial Services Firms and Employees Avoid FCPA Liability?

Aug. 7, 2013

Seven Lessons from China’s Bribery Investigation of GlaxoSmithKline

Jul. 24, 2013

U.K. Practitioners Discuss the Prospect of Enforcement Actions Under the U.K. Bribery Act, Advantages of Deferred Prosecution Agreements and Proposed Sentencing Guidelines

Jul. 10, 2013

Seven Key Trends That Are Changing the FCPA Enforcement and Compliance Landscape

Jun. 26, 2013

Acting Assistant Attorney General Raman Highlights DOJ Commitment to FCPA Enforcement

Jun. 26, 2013

OECD Working Group’s 2013 Report on Global Anti-Bribery Efforts Shows Lackluster Performance

May 29, 2013

Top Government and Private FCPA Practitioners Discuss Global Enforcement, Self-Reporting, Facilitation Payments, M&A Due Diligence, Jurisdiction and NPAs

Apr. 3, 2013

SEC’s FCPA Unit Chief and Top Practitioners Address the Role of Financial Controls in FCPA Compliance Policies, Internal Investigations, Self-Reporting and Related Topics

Apr. 3, 2013

Lessons from the Latest Anti-Corruption Developments in the U.K., Brazil and China

Mar. 6, 2013

Knowing Your Partners: Three Steps to Reduce FCPA Risk from Third Party Intermediaries

Jan. 23, 2013

In Possible Sign of Escalation of Canadian Anti-Bribery Enforcement, Griffiths Energy Agrees to Pay $10.35 Million to Resolve CFPOA Charges

Jan. 23, 2013

Combating Bribery North of the 49th: A Wake-Up Call for Companies Doing Business in Canada

Dec. 12, 2012

Recent Developments in U.K. Bribery Act Enforcement: SFO Head Green Speaks, Abbot Group Settles and Rolls-Royce Reveals Bribery Investigation

Nov. 28, 2012

Top Government Officials Discuss FCPA Enforcement Actions Initiated During 2012 and Their Significance

Nov. 7, 2012

ABA Panel Focuses on Trends in SEC Enforcement of the FCPA and Strategies for Negotiating Civil FCPA Settlements

Nov. 7, 2012

Kroll Survey Identifies Global Fraud Trends and Risks in Europe, the Middle East and Africa

Nov. 7, 2012

Litigation, Settlement and Risk Management Lessons Learned from Recent FCPA Trials

Oct. 3, 2012

Why the Current Regime Is Effective at “Busting Bribery”: An Interview with Professor Dan Danielsen, Co-Author of the Open Society Foundations’ Report on Corruption

Oct. 3, 2012

Anti-Corruption Compliance in the Age of Global Enforcement

Sep. 19, 2012

Chief of the DOJ’s Criminal Division Defends the Use of Deferred Prosecution Agreements in FCPA Enforcement Actions

Sep. 19, 2012

Transparency International Reports “Inadequate” Worldwide Enforcement of OECD Anti-Bribery Convention

Sep. 5, 2012

Grant Thornton Webinar Highlights FCPA and U.K. Bribery Act Enforcement Trends (Part One of Two)

Sep. 5, 2012

Fines, Victims, the Three Buckets of FCPA Costs and FCPA Reform: An Interview with Mike Koehler, the FCPA Professor (Part Two of Two)

Aug. 22, 2012

Compliance Implications of the Current Enforcement Climate: An Interview with Mike Koehler, the FCPA Professor (Part One of Two)

Aug. 8, 2012

Shearman & Sterling Report Identifies Trends in FCPA Enforcement

Jul. 25, 2012

International Corruption Risks Facing Financial Institutions

Jul. 25, 2012

Corruption and the Arab Spring: Compliance Implications for International Companies

Jul. 25, 2012

Hughes Hubbard Analyzes Trends and Extracts Lessons from Recent FCPA Enforcement

Jul. 25, 2012

An Interview with Judge Stanley Sporkin, the “Father of the FCPA” (Part Two of Two)

Jul. 11, 2012

An Interview with Judge Stanley Sporkin, the “Father of the FCPA” (Part One of Two)

Most-Read Articles

Oct. 30, 2019
New DOJ Guidance Offers a Gentler Standard on Inability-to-Pay Claims
- Enforcement Trends
Jul. 24, 2019
How the World’s Most Ethical Companies Are Aligning Corporate Culture and Strategy
- Compliance Culture
Nov. 13, 2019
In New Guidance, SFO Outlines Internal Investigation Expectations
- Internal Investigations
Sep. 18, 2019
SFO Guidance Moves Toward Transparency but Offers No Guarantees
- Enforcement Trends
Oct. 16, 2019
In New Guidance, SFO Indicates It Wants Companies to Waive Privilege
- Privilege