As the DOJ’s commitment to sanctions enforcement grows, the stakes are potentially very high. As Deputy Attorney General Monaco explained, the old ways of managing sanction risks may no longer be sufficient to address the
Continue Reading DOJ plans to make US sanctions enforcement “the new FCPA”: watch these key areas
To help stop coronavirus disease 2019 (COVID-19) from spreading, governments around the world have required businesses to close and, where possible, to require their employees to work from home. In the wake of this closure,
Continue Reading Coronavirus: reopening businesses – compliance risks
Dealing a significant blow to US prosecutors, the US Court of Appeals for the Second Circuit has ruled that a non-resident foreign national, operating entirely outside the physical territory of the United States, cannot be
Continue Reading The Second Circuit rules against DOJ’s aggressive assertion of extraterritorial FCPA jurisdiction over foreign accessories
When carrying out internal investigations into Foreign Corrupt Practices Act (FCPA) or other bribery issues, multinational employers may find themselves investigating alleged wrongdoing that occurred in more than one country. Lawyers and HR personnel, who
Continue Reading International HR and employee discipline issues in FCPA matters
With the widespread adoption of “super-apps”, multinational companies operating in China and other emerging economies may be exposed to heightened compliance risks, particularly in light of the recent adoption of a new US Foreign Corrupt
Continue Reading Smartphone apps pose heightened compliance risks under new US FCPA Corporate Enforcement Policy
