Even though the government has been encouraging companies to voluntary disclosure Foreign Corrupt Practices Act (and other) issues for approximately 20 years, every few years it seems the DOJ tweaks it voluntary disclosure and related corporate criminal enforcement policy.
The latest example occurred in January 2023. (See here for the prior post).
As long as
As highlighted in this prior post, in September 2022 the DOJ announced that two Marshall Island nationals (Cary Yan and Gina Zhou) arrived in the U.S. after being extradited from Thailand based on 2020 criminal charges that the individuals violated the Foreign Corrupt Practices Act (and other laws) in connection with an alleged scheme to
Recently Deputy Attorney General Lisa Monaco delivered this speech at the American Bar Association National Institute on White Collar Crime.
Topics discussed included: “inspiring a culture of compliance,” “promoting compliance through compensation and clawback programs,” and “accountability.”
Monaco began her speech as follows:
“It’s a pleasure to be here to talk to you about an enduring
Do some FCPA commentators just make sh*t up and hope nobody notices?
This Forbes article by Robert Anello is titled “FCPA Cops Back On The Beat: DOJ Touts Reenergized Enforcement Efforts,” is full of false and misleading information.
For instance, the article asserts: “In 2021 and 2022, Biden’s DOJ resolved a meager total of only
Yesterday Acting Principal Deputy Assistant Attorney General Nicole Argentieri delivered this speech at the annual FCPA dog and pony show.
The speech touched on three issues: (i) the “Criminal Division’s continued cooperation with our international partners and … how [the DOJ] is expanding those relationships to combat corruption and other offenses; (ii) “recent FCPA enforcement actions
I have no doubt that the individuals associated with Transparency International have a genuine interest in reducing bribery and corruption in the global marketplace.
Nevertheless, I have long had good-faith concerns (see prior posts here, here, here, here, here and here) about how TI goes about this task.
The latest
In her recent speech in connection with release of a memo to DOJ personnel titled ““Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group” Deputy Attorney General Lisa Monaco stated:
“Voluntary self-disclosure programs, in various Department components, have already been successful. Take, for example, the Antitrust Division’s Leniency Program,
In July 2020, NewAge Inc. (a health and organic products company) announced a definitive agreement to acquire ARIIX, together with four additional companies in the e-commerce and direct selling channels, to “create a global firm with estimated pro forma revenues in excess of $500 million across more than 75 countries worldwide.”
As highlighted in this
Today’s post is from Debevoise attorneys Andrew Levine, Matthew French, and Nestor Almeida.
In recent years – and notwithstanding encouraging windows of progress – economic difficulties, political shifts, and the pandemic’s lingering effects have undercut anti-corruption efforts in Latin America. The fourth annual Capacity to Combat Corruption Index (“CCC Index”), published in
Kroll’s recent 2022 Anti-Bribery and Corruption Benchmarking Report caught my eye (and not just because it contains beautiful photography of slot canyons and Moab, Utah area attractions such as Delicate Arch – from different vantage points – and Corona Arch).
According to the report:
“In February 2022, Kroll analyzed data from 100 U.S. and Canadian