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On January 17, 2020, the United Kingdom’s Serious Fraud Office (“SFO”) published new guidance regarding how the office assesses the compliance programs of organizations that are under investigation…

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…

The recent bribery conviction of British citizen Lawrence Hoskins created a stir among white collar practitioners because it showed that the US Department of Justice (“DOJ”) could be successful using…

On November 7, 2019, a Second Circuit panel 1 heard oral argument on whether the use of United States wire services in effecting a bribery scheme is enough, without more, to pull defendants within…

The Criminal Information against two former executives of Unaoil, Inc. was unsealed on October 30, 2019, laying out the U.S. government’s case against them for facilitating bribes on behalf of…

Sarah Lawson, the General Counsel of the U.K.’s Serious Fraud Office (“SFO”), recently emphasized that corporate compliance functions must be well resourced and that the SFO expects such programs…

The U.S. Commodity Futures Trading Commission (“CFTC”) is entering the fight against foreign bribery and corruption.

In a significant departure from previous practice, the Department of Justice (“DOJ”) imposed a corporate monitor on a company even after it engaged in extensive remedial measures and enhanced its…

On Monday, March 25, 2019, in a brief order without any dissents, the Supreme Court denied certiorari in In re Grand Jury Subpoena , 1 the case also known as the “Mueller Mystery Case” because the…

Last week, the DOJ updated its guidance to the Foreign Corrupt Practices Act (“FCPA”) and in doing so tweaked its de-confliction advice.

Last week, the Department of Justice (“DOJ” or “Department”) made a series of changes to the 2017 FCPA Corporate Enforcement Policy (“Policy”) contained in the Justice Manual (until last year, known…

DOJ has again modified its guidance regarding enforcement of the FCPA. Among the recent modifications is a loosening of the ban it had announced in 2017 on the use of disappearing messaging…