The Man From FCPA

While it may seem daunting to convince third parties to agree to the company’s terms and conditions, it’s a key part of compliance and one each party will appreciate in the end.

Glencore has seen a drop in its share price, which could be related to the Justice Department having issued a subpoena for possible FCPA violations in the Democratic Republic of Congo, Nigeria, and Venezuela.

Compliance practitioners take note: Cooperating with FCPA investigators was literally worth millions to Panasonic Aviation.

For those who might have wondered if the Jeff Sessions’ Justice Department was going to enforce the Foreign Corrupt Practices Act, that question seems to have been answered in the affirmative.

One of the key goals of any FCPA compliance program is to train company employees in awareness and understanding of the FCPA itself.

The recent arrest of an italian citizen in Germany, a former VW employee, may mean the government intends to bring charges against lower-level employees in an attempt to get them to flip on senior employees who were involved in the fraud.

A look at Hui Chen’s career at the Department of Justice, serving as the compliance counsel and, most importantly, putting the compliance function front and center in the fight against FCPA violations.

A small percentage of the audience at Compliance Week 2017 had read the Justice Department guidance on evaluations. What are they missing, and why the delay?

Tom Fox looks at the Justice Department’s “Evaluation of Corporate Compliance Programs,” an 11-part list of questions that encapsulates the Justice Department’s most current thinking on what constitutes a best practices compliance program.

Perhaps it’s not the penalties and fines, but rather the individual prosecutions that deter bad behavior. The Man From FCPA Tom Fox reports.

As the recent arrest of another VW executive (this time in the United States) unfolds, The Man From FCPA Tom Fox ponders whether VW will actively assist U.S. law enforcement authorities in performing a substantive internal investigation.

Getting credit for cooperating with the Department of Justice is getting a whole lot tougher. Tom Fox explores.

Tom Fox questions whether U.S. regulators missed a chance to illustrate how they would give credit for anti-corruption prosecutions done by other governments in the case of GlaxoSmithKline’s China subsidiary’s recent FCPA resolution.

A look at potential VW criminal resolutions brings up several questions, says Tom Fox, around  type of resolution; individual liability; and more. Will this test the DoJ’s Yates Memo?

Plot twist! The Wolf of Wall Street, a movie about corruption on Wall Street, might have been funded by corrupt money. Suddenly, this is starting to sound more like Inception.

It appears the Fédération Internationale de Football Association is trying to shed its corrupt image in favor of playing the victim. The international governing body of football has asked the Justice Department for its share of monies it obtains through forfeiture and penalties from individuals prosecuted around the FIFA corruption scandal. But has the entity put any work into cleaning up its own house before seeking help? FCPA blogger Tom Fox explores.

Two weeks ago, Foreign Corrupt Practices Act enforcement took a formal turn when the Justice Department released the Yates Memo, which formalized the department’s new focus on prosecuting individuals under the FCPA. In the same week, there was a much less reported event that could have equally large effect on FCPA enforcement going forward. Our Man from FCPA has more inside.