Summary of Compliance Guideline The Criminal Division’s Fraud Section of the U.S. Department of Justice (the “DOJ”) has released guidance on how the DOJ will determine the effectiveness of a company’s corporate compliance program. The guidance, entitled Evaluation of Corporate Compliance Programs[1] (the “Compliance Guideline”), provides examples of topics and sample questions that are frequently … Continue Reading
The United Kingdom’s regime against bribery, corruption and fraud is operating in a new landscape following the introduction in August 2015 of the International Corruption Unit (ICU), a new governmental agency created under the auspices of the Department for International Development (DFID). The latest step in the clampdown on nefarious business practices came as the … Continue Reading
The UK’s Serious Fraud Office (“SFO”) has launched a formal criminal investigation into GlaxoSmithKline (GSK) and its “commercial practices”, understood to mean allegations of foreign bribery. David Green CB QC, Director of the SFO, said back in 2012 that only the largest cases, that prevented UK companies from competing for big contracts on a level … Continue Reading
Magyar Telekom Plc and its majority owner Deutsche Telekom AG have agreed to pay a total of approximately $95 million in penalties arising from alleged violations of the anti-bribery and books and records provisions of the Foreign Corrupt Practices Act (“FCPA”) stemming from conduct in Macedonia and Montenegro. Conduct Between 2005 and 2006, former executives … Continue Reading
Aon Corp., an Illinois-based world leader in risk management, insurance, and reinsurance brokerage services, has entered into a Non-Prosecution Agreement (“NPA”) with the Department of Justice (“DOJ”) and has settled a civil action brought by the Securities and Exchange Commission (“SEC”) stemming from alleged violations of the anti-bribery, books and records, and internal controls provisions … Continue Reading
Last week, various stories were published in the United States about Renault’s claims that 3 senior employees were being investigated for leaking not-yet-patented electric car battery technology secrets in a case where Chinese interests may be implicated. Details have been sparese however, leaving unaddressed key questions such as whether the Renault employees are alleged to have released … Continue Reading
