There’s no room for clowning about when it comes to risk management and maintaining the integrity of international business. According to records of ancient Chinese history, the armies of the Chu and Song states were facing each other in readiness for battle in 630 BC when a Chu warrior, Xiong... Read More

There were only three FCPA enforcement actions in the first quarter of 2019, but the small number obscures a bigger threat to corporate bottom lines—fines totalling $1.1 billion. This figure eclipses the total settlements in Q1 2018—also for three corporate enforcement actions—of a... Read More

2018 has been a record year of penalties issued for breaches of the Foreign Corrupt Practices Act (FCPA). Settlements totaling more than $2.96 billion were agreed by corporations found to be in breach of the Act. The year saw further indications of the FCPA’s global reach, witnessed the first judgments... Read More

Petrobras has reached a $1.78 billion settlement with the DOJ and SEC over bribes to politicians and political parties in Brazil. This is the first time an enforcement action over FCPA violations has exceeded a billion dollars. The amount is bigger than the nearest two settlements combined, and the case... Read More

The U.S. Corporate Enforcement Policy, which incentivises companies to self-disclose bribery and corruption when they come across it, now applies to U.S. companies which are merging with or acquiring foreign companies. That’s according to a recent speech by a senior official at the Department of... Read More

Just three years ago, Teva Pharmaceuticals, a drug-maker in Israel, disclosed to both the U.S. Securities & Exchange Commission and the U.S. Department of Justice that an on-going internal probe had revealed possible violations of the Foreign Corrupt Practices Act (FCPA) and/or local laws. Ultimately... Read More