Posts Tagged ‘FCPA’

Sessions Dodges, Weaves, Promises on FCPA

Attorney General Jeff Sessions promised yet again Monday to enforce the FCPA and other anti-corruption laws, in a wide-ranging speech meant to win over corporate compliance officers curious about how seriously the Trump Administration will take corporate misconduct. Sessions spoke to an audience of several hundred at the Ethics & Compliance Initiative’s annual conference in…

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Top FCPA Cop Speaks Again on FCPA

Compliance officers got another glimpse into the future of FCPA enforcement this week, with the Justice Department’s top anti-corruption prosecutor giving his most extensive comments yet on the subject. Those comments, delivered Tuesday by deputy assistant attorney general Trevor McFadden, was reassuring and frustrating at the same time. On one level, McFadden hit all the…

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SEC’s FCPA Enforcement Chief to Leave

Kara Brockmeyer, head of the FCPA Enforcement unit at the Securities and Exchange Commission since its creation in 2011, will leave her job later this month. The SEC announced the news in a press release on April 4. The statement didn’t say where Brockmeyer may go next or why she is leaving, although Brockmeyer is only…

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Walmart FCPA Update: $837 Million

Another year, another eye-popping amount of money spent by Walmart on its long-running FCPA investigation—with no end in sight. Walmart spent $99 million on FCPA matters last year, according to the annual report it published March 31: $80 million for the investigation itself, plus another $19 million spent on “enhancements to its global compliance program.”…

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SEC Nominee on FCPA, Compliance Costs, More

The Senate Banking Committee held its confirmation hearing today for Jay Clayton, the Trump Administration’s nominee to chair the Securities and Exchange Commission. We have a few nuggets of detail worth an ethics & compliance officer’s attention, although the hearing mostly unfolded along predictable lines. On one side were Clayton and Republican members of the…

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FCPA: Pilot Program Extended, and Much More

Compliance officers may feel a bit dizzy today—we’ve had a whirlwind of news related to the Foreign Corrupt Practices Act this week, particularly in the last 24 hours. From the Pilot Program, to voices of support within the Trump Administration, to fresh FCPA arguments in court, and that bizarro news about the U.S. attorneys, we…

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Report: 2016 Was Good Year for Anti-Corruption

TRACE International has published its latest review of global anti-corruption enforcement, touting a dramatic increase in enforcement last year, led by U.S. authorities. Enforcement activity essentially doubled last year, according to the organization’s annual Global Enforcement Report. There were 255 investigations into bribery of foreign officials conducted by 29 countries as of Dec. 31, 2016.…

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Deeper Dive Into New DoJ Compliance Guidance

Yesterday I did another “Compliance in the Weeds” podcast with Tom Fox, where our subject of conversation were the Justice Department’s new guidelines for evaluating corporate compliance programs. That guidance—46 questions that prosecutors might ask about your compliance program, across 11 broad categories—is manna from heaven for corporate compliance officers. The questions are specific. They…

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Fresh FCPA Guidance From Justice Dept.

Hallelujah! We have fresh guidance from the Justice Department about an effective FCPA compliance program, and a speech from a new official there who says enforcement will continue! And we all thought the Trump Administration could get nothing done. The guidance is an 11-part checklist apparently added to the Fraud Section’s website sometime last week.…

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Compliance in Trump Era: More Markers Placed

Compliance officers trying to figure out how your job will or won’t change during the Trump Administration, look at two events that happened this week. First, Jeff Sessions was confirmed as attorney general. Second, the Trump Administration and its henchmen put the Conflict Minerals Rule in their sites. Within those two things are all the…

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