September is a great month. The heat and humidity of July and August have largely subsided, evenings are crisp and cool, the leaves begin to change, the kids go back to school, college football returns to campus, and oh those honeycrisp apples!
As highlighted in this post, historically September has tended to be an active
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement
So-called “declinations with disgorgement” (first used by the DOJ in a Foreign Corrupt Practices Act in 2016) are just another resolution vehicle – among others – used by the DOJ to resolve alleged instances of FCPA scrutiny.
The latest example concerns Boston Consulting Group.
An August 27th letter from the DOJ to the company’s counsel
When compiling a list of the industries that have the highest Foreign Corrupt Practices Act risk, the aviation industry is probably not going to be near the top of many lists.
However, it should be because as highlighted in this post there have been approximately 20 corporate FCPA enforcement actions against companies in the industry
Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of professionals from around the world. The FCPA Institute began as an in-person event, but shifted to Zoom in 2020. The Zoom event is time and cost efficient and has resulted in greater participation from professionals around the world.
The DOJ has a specific website devoted to the Foreign Corrupt Practices Act.
On the site you will find a purported chronological list and alphabetical list of Enforcement Actions.
With any free website (let alone a government website), there is probably not an expectation that the website be updated every day or perhaps every
As highlighted here, in September 2020 the DOJ announced that Javier Aguilar (a former employee of Vitol Inc.) was criminally charged for “his alleged participation in a five-year international bribery and money laundering scheme involving corrupt payments to Ecuadorian officials.” (In December 2020, Vitol resolved a net $90 million Foreign Corrupt Practices Act enforcement action for
So-called “issuers” under the Foreign Corrupt Practices Act (that is generally companies with shares traded on a U.S. exchange or otherwise with reporting obligations to the Securities and Exchange Commission) are subject to both Securities and Exchange Commission and Department of Justice FCPA enforcement.
However, many FCPA enforcement actions against issuers are SEC only and
This recent post highlighted the DOJ’s new Corporate Whistleblower Awards Pilot Program. (See here for 14 pages of guidance, and see here for the 4 page fact sheet).
To be eligible for an award, information provided by an individual must, among other things, “pertain” to four subject matter areas – one of which is “foreign
Shelf space at a grocery store or other retail store is probably not something one thinks much about.
Until one does.
A recent article in the Wall Street Journal titled “Grocers Get Picky on Shelf Space for Suppliers” highlights how the “contest for supermarket and grocery shelf space is heating up as brands
