FCPA compliance

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FIFA, the DOJ and the Global Fight Against Corruption

The first step to recovery is admitting you have a problem. Let's grab onto that metaphor. Despite corruption that's been endemic for years, FIFA has not only not yet taken that first step, the organization is still balancing precariously on wobbly legs. With the DOJ having recently charged more than a dozen FIFA officials, however, the ...


The Attorney-Client Privilege in FCPA Internal Investigations

We all have at least a cursory understanding of attorney-client privilege, whether through our own legal dealings or from catching an episode of Law & Order now and then. Latin-American countries are beginning to learn the importance of the concept in the midst of FCPA investigations. Lesson one: how do we structure the review? And what ...


FCPA Perspectives – What is Old is New

The U.S. government has been battling corruption for four decades through the Foreign Corrupt Practices Act, and in that time, some on the front lines of international business may have grown so accustomed to hearing about FCPA compliance that it begins to sound like white noise. Let's not let our guard slip... FCPA compliance is more crucial now ...

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The FIFA Indictments and Travel Act Prosecutions under the FCPA

Last week, 14 officials and individuals associated with FIFA were indicted on corruption, racketeering, and conspiracy charges. And while the defendants haven't exactly violated the FCPA, U.S. authorities are bringing charges under the Travel Act, which prohibits the use of the mail or any facility in interstate commerce to engage in illegal activity.


Anti-Corruption Reform Moving Forward in Mexico

Think about the Mexican government and likely the first word that springs to mind is "corrupt." It's an association the country is working to overcome, evidenced by the imminent implementation of a National Anti-Corruption System. The government's reputation for corruption will no doubt take years to correct, but they're on their way.

sec enforcement

SEC Enforcement and Compliance Priorities 2015

SEC enforcement actions have been on the rise for some time, a pattern that's only likely to continue given recent developments. The agency is more willing than ever to take cases to court, and last year saw the single largest whistleblower award to date. Bradley Bondi, SEC compliance and enforcement expert, outlines the agency's focus for 2015.

international law

Assuring Regulatory Compliance Doesn’t Get Lost in Translation

With the expansion of large multinational corporations into developing countries, a proliferation of global regulatory enforcement actions, including anti-bribery and anti-corruption, has risen. Executives, including general counsel, compliance and risk officers, are smart to plan in advance for potential regulatory investigations.

fcpa tom fox

Deep Dive: SEC Enforcement of the FCPA

FCPA practitioners often focus only on DOJ enforcement issues. This article provides a deep dive into some of the key differences between DOJ enforcement of the FCPA with that of the SEC.

Mr. Spock

Farewell to Mr. Spock and Risk Assessment Under COSO

Mr. Spock and his pursuit of logic inform today’s blog post. Every compliance practitioner is aware of the need for a risk assessment in any best practices compliance program; whether that program is based on the US Foreign Corrupt Practices Act (FCPA), UK Bribery Act or some other compliance law or regime.