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In today’s corporate environment, it is no longer enough to just have a compliance program on file. Proper and timely training, focus on high-risk roles, and working alongside your compliance team are critical.

Zach Terwilliger offers his insight into shifts in enforcement policies and the unique challenges spawned by the COVID-19 pandemic in this month’s Financier Worldwide Magazine fraud and corruption feature titled “White-collar crime in the post-COVID-19 landscape.”

On April 12, 2021, President Joe Biden nominated Kenneth Polite Jr. as Assistant Attorney General for the Criminal Division at the Department of Justice (“DOJ”).

In a striking rebuke, the U.K. Supreme Court found that the U.K. Serious Fraud Office (“SFO”) overstepped its authority when it tried to access corporate documents from the United States.

A recent enforcement action announced by the Antitrust Division of the U.S. Department of Justice included a notable plot twist – the investigation did not turn up an antitrust crime, but instead revealed a criminal conspiracy to violate the Procurement Integrity Act (“PIA,” 41 U.S.C. §§ 2101-2107).

A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded.

Mere months after Airbus entered into a record-breaking, nearly $4 billion resolution with the U.S., U.K., and France to settle foreign bribery allegations, the U.K.’s Serious Fraud Office (“SFO”) moved on July 30, 2020, to bring additional corruption charges against Airbus.

On July 3, 2020, the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) published the Second Edition of “FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act” (the “Guide”).

The SEC’s authority to seek disgorgement has been a spotlight issue for the last several years, and on June 22, 2020, the Supreme Court delivered a highly anticipated ruling that will have a mixed impact.

On June 25, 2020, V&E partner Fry Wernick spoke on a Wall Street Journal / Dow Jones Risk & Compliance panel entitled, “Lessons from Recent Compliance Failures.”

In a novel and aggressive move likely aimed at garnering goodwill with federal regulators, Venezuelan state-owned entity CITGO Petroleum Company (“CITGO”) has sued its former agent for harm CITGO alleges was caused by the agent’s payment of bribes to foreign officials.

Last week, the U.S. Securities and Exchange Commission (the “SEC”) initiated its third try to pass a rule on “Disclosure of Payments by Resource Extraction Issuers,” 1 which would govern the…