Anti-bribery and corruption failures in financial institutions rarely stem from bad policies.
Anti-Bribery
Posted inAnti-Bribery
Tariff evasion enforcement: The new FCPA
Companies that import goods into the United States will face heightened enforcement scrutiny for attempted acts of customs fraud, including tariff evasion, under the Trump administration. Thus, chief compliance officers and in-house counsel face a new kind of pressure to ensure they are mitigating risk in this area.
Posted inAnti-Bribery
SFO sharpens framework for judging compliance programs in bribery and fraud cases
The U.K. Serious Fraud Office (SFO) has updated its guidance about how it evaluates corporate compliance programs when considering whether to prosecute or offer leniency to companies that have breached bribery and corruption laws.
Posted inAnti-Bribery
The FCPA’s origin story: Why “Bribery Beyond Borders” is essential reading
I have often thought the facts of many Foreign Corrupt Practices Act (FCPA) enforcement actions would make the basis for a great series of crime-thriller books. But it turns out the origins of the FCPA itself are as dynamic, fast-paced and exciting as any such work of fiction.
Posted inAnti-Bribery
DOJ secures $118 million penalty in FCPA violation case tied to Guatemalan telecom firm
The parent company of a telecom subsidiary in Guatemala agreed to pay $118.2 million to settle allegations of improper payments made to government officials, but the U.S. Department of Justice chose not to impose a compliance monitor to administer the firm’s compliance with the Foriegn Corrupt Practices Act (FCPA).
Posted inAnti-Bribery
Part One: A case-by-case analysis of FCPA investigation closures
Foreign corruption enforcement relating to national security matters has been a common theme under the Trump administration. A second common theme continues to be the discrete way in which the DOJ has ended several FCPA investigations.
Posted inAnti-Bribery
Texas gas company found that its merger acquisition paid a cartel-connected entity
A Texas-based gas company has disclosed that a Mexican affiliate made payments to local government officials that may have benefited a cartel designated as a terrorist group by the U.S. government. Entanglement with cartels is an increasing risk for companies doing business in Mexico.
Posted inAnti-Bribery
Navigating 2025 Compliance Challenges: Laurie Waddy on Governance, Anticorruption Trends, Vendor Risk, and AI Compliance
Former Head of Compliance/Chief Compliance Officer Laurie Waddy believes compliance professionals are well-positioned to support artificial intelligence (AI) adoption in their organizations. Drawing on 25 years’ experience in legal and compliance roles across multiple industries, Waddy shares insights into top compliance trends confronting the profession, including the emerging compliance risks related to AI implementation.
Posted inAnti-Bribery
DOJ declines to prosecute Liberty Mutual in $4.7M FCPA bribery case
Liberty Mutual agreed to give up $4.7 million in profit – the amount it earned from a bribery scheme uncovered by the government – as part of a settlement related to the Foreign Corrupt Practices Act, according to a letter from the U.S. Department of Justice.
Posted inAnti-Bribery
DOJ targets $14.6B in health care fraud with focus on transnational crime
Emerging enforcement priorities of the U.S. Department of Justice’s health care fraud division align with the Trump administration’s emphasis on prosecuting transnational criminal organizations and ending opioid trafficking.
