Lessons From Glencore Settlement

Glencore

Earlier this week Swiss commodities trading giant Glencore gave the compliance community a doozy of a corporate corruption settlement, agreeing to pay more than $1 billion to regulators around the world for bribery and market manipulation that lasted more than a decade. I’ve been sifting through the settlement documents since then and we have several…

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Some Polite Words on Testing

fcpa

Gather round, corporate compliance professionals. We have another speech from a high-ranking Justice Department official about how compliance programs should work, and as usual these days, the speech is full of clues that are well worth your time and attention. The speech came from Kenneth Polite, assistant attorney general for the Criminal Division, who spoke…

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FCPA Reminders From Stericycle

Stericycle, the global medical waste giant, has agreed to settle FCPA charges against the company for widespread bribery in Latin America, giving the rest of us another case with lessons about the risks of rapid international growth and poor corporate culture. The settlement was announced Wednesday. Stericycle will pay $84 million in penalties to the…

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KT Pays $6.3M to End FCPA Case

KT

Compliance professionals have quite the FCPA case to consider this week, courtesy of the Securities and Exchange Commission hitting Korea’s largest telecommunications carrier with $6.3 million in penalties and disgorgement for all manner of corrupt practices in the 2010s. The company, KT Corp., has a long history of corruption. KT agreed to settle the SEC…

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Study: CCOs Put DOJ Guidance to Use

compliance

A study released this week finds that most chief compliance officers are aware of, and appreciate, the guidance on effective corporate compliance programs that the Justice Department has churned out in recent years — although CCOs would like more examples from the department of decisions not to prosecute a company based on its compliance efforts. …

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Biden Admin Unveils Anti-Corruption Strategy

anti-corruption

The Biden Administration has released its strategy on countering corruption around the world, with lots of talk about cross-border collaboration, data collection, and tougher U.S. enforcement; but relatively little about new legislation that might add fresh burdens to anti-corruption compliance programs.  The White House released the strategy document, 38 pages long, on Monday morning. It…

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China’s New Anti-Corruption Maneuver

anti-corruption

It seems that China is revising its anti-corruption rules to give it a stronger hand in prosecuting overseas corporations that bribe government officials, in case you need yet another headache in your compliance officer life.  We don’t know the exact details of the new rules or even have a copy of them available to the…

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That Lawsuit Against J.P.Morgan

JP Morgan

As you might have already heard (because compliance is such a gossipy profession), last week a former compliance officer for J.P.Morgan filed a lawsuit against the bank, accusing executives there of retaliating against her because she was raising concerns about failures and weaknesses in the compliance program.  I spent the weekend reading the complaint, which…

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The Swiss Angle in Credit Suisse

Credit Suisse

I want to circle back to that FCPA enforcement action against Credit Suisse a final time, because we have one more detail of this case that hasn’t yet been discussed much. We haven’t talked about the restrictions that Swiss regulators have imposed on Credit Suisse’s future business activities. To recap, last month Credit Suisse settled…

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Some Tips for Handling FCPA Cases

fcpa

Today we have a few suggestions for how to resolve FCPA cases with the Securities and Exchange Commission, courtesy of a securities enforcement virtual forum that took place Thursday. One point that compliance officers will appreciate hearing: you, rather than defense counsel, should be the ones in the room with the SEC to explain why…

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