Tag Archives: Compliance Program

Rosenstein Pledges Reduced Regulation, Encourages Self-Reporting

U.S. Deputy Attorney General Rod Rosenstein pledged an enforcement environment in which businesses can thrive. In keynote remarks at the U.S. Chamber Institute for Legal Reform, he emphasized the Department of Justice’s (DOJ) commitment to “avoiding unnecessary interference in law-abiding enterprises.” Rosenstein also promoted the benefits of corporate compliance and self-reporting. Although allegedly offering “no breaking news” about DOJ policies, … Continue Reading

Summary of U.S. Department of Justice’s Guidance, “Evaluation of Corporate Compliance Programs”

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

DOJ’s Criminal Division Launches new FCPA Pilot Program

In an effort to enhance its ability to investigate and prosecute Foreign Corrupt Practices Act (FCPA) cases, the Department of Justice’s (DOJ) Criminal Division has launched a new one-year FCPA pilot program effective April 5, 2016. The program has three main goals: Motivate companies to voluntarily self-disclose FCPA-related misconduct Motivate companies to fully cooperate with … Continue Reading

UK Serious Fraud Office launches investigation into GlaxoSmithKline in relation to claims of foreign bribery

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

Practical Guidance on How to Conduct FCPA Due Diligence

The Department of Justice and Securities and Exchange Commission have stressed the need for companies to conduct FCPA due diligence before entering into transactions with third parties or buying another company.  The DOJ and SEC have levied stiff fines on companies that have not heeded their advice once violations of the FCPA have been discovered.  … Continue Reading

Monthly China Anticorruption Update Report– April 2012

The most recent FCPA and anticorruption enforcement developments involving the People’s Republic of China (PRC) are summarized below.  Thanks as always to Squire Sanders Shanghai office for monitoring and reporting on these enforcement actions. China Enforcement Actions (1) On March 31, 2012, Li Ping, former Party chief of Futian District committee, wassentenced to six-and-a-half years … Continue Reading
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