Recent enforcement actions offer guidance on what the Department of Justice considers to be an “imminent threat” of disclosure or government action, what it means by “prompt” disclosure, and how a company can earn credit for revealing all relevant facts.
Anti-Bribery
Posted inAnti-Bribery
LRN survey: Compliance programs shifting focus from bribery, corruption
Many ethics and compliance programs have refocused their efforts away from bribery and corruption and onto data security and privacy, complex government regulations, artificial intelligence security, and other contemporary challenges, a survey from LRN found.
Posted inAnti-Bribery
New SFO director vows quicker cases, stumps for whistleblower payouts
“Under my leadership, the SFO will be bolder, more pragmatic, more proactive,” said Nick Ephgrave in his first public speech as head of the U.K. Serious Fraud Office.
Posted inAnti-Bribery
Insurance broker Gallagher off hook in DOJ FCPA probe
Arthur J. Gallagher disclosed the Department of Justice ended an investigation into the insurance broker’s business in Ecuador for potential violations of the Foreign Corrupt Practices Act.
Posted inAnti-Bribery
Raytheon parent discloses indications of improper payments in Middle East
RTX Corp., parent company of aerospace and defense giant Raytheon, disclosed an internal investigation launched into potential improper payments in connection with contracts in the Middle East found indications of misconduct.
Posted inAnti-Bribery
Calavo Growers discloses potential FCPA issues
Multinational produce and agriculture company Calavo Growers disclosed in an annual filing an investigation into its Mexico operations found potential issues under the Foreign Corrupt Practices Act.
Posted inAccounting & Auditing
FCPA violations in China: Lessons learned from 2023 cases
Enforcement actions regarding alleged violations of the Foreign Corrupt Practices Act at 3M, Albemarle, Clear Channel Outdoor, and Royal Philips each had China touchpoints. Experts assess third-party risk management lessons learned from each case.
Posted inAnti-Bribery
Lessons from Albemarle, ABB: How data-driven compliance can help your firm
Andrew McBride, chief risk officer of Albemarle Corp., and Tapan Debnath, head of integrity, regulatory affairs and data privacy at ABB, discussed how and why their respective organizations use data analytics to conduct business as part of a recent webcast.
Posted inAnti-Bribery
RDx Bioscience, CEO settle kickback case for $13M
New Jersey-based clinical laboratory RDx Bioscience and its chief executive officer agreed to pay more than $13 million to the Department of Justice to settle illegal kickback allegations.
Posted inAnti-Bribery
SDNY launches whistleblower pilot program
The U.S. Attorney’s Office for the Southern District of New York took its efforts to encourage voluntary self-disclosure a step further with the launch of a whistleblower pilot program for individuals involved in nonviolent offenses.
