Global Investigations Review - The law and practice of international investigations

Editor's picks

Eight companies have publicly self-reported FCPA violations under the pilot programme

Eight companies have publicly self-reported FCPA violations under the pilot programme

October 25, 2016, Just Anti-Corruption

At least eight companies have self-reported potential Foreign Corrupt Practices Act violations since the US Department of Justice announced its new leniency programme in April, according to an analysis by Just Anti-Corruption.

DOJ introduces version of FCPA pilot programme for sanctions cases

DOJ introduces version of FCPA pilot programme for sanctions cases

October 21, 2016, Just Anti-Corruption

In what appears to be a vote of confidence for the FCPA pilot programme, which was introduced in April to encourage companies to confess foreign bribery violations, a second section of the DOJ has now implemented its own version of the self-reporting scheme.

Lawyers play down significance of ISO anti-corruption compliance standard

Lawyers play down significance of ISO anti-corruption compliance standard

October 20, 2016, Just Anti-Corruption

Top officials from the US Department of Justice and Securities and Exchange Commission have spoken positively of the ISO's standard for anti-bribery compliance. But since its release in October defence lawyers have voiced scepticism about the standard's importance.

Och-Ziff FCPA case highlights tension in SEC admissions policy

Och-Ziff FCPA case highlights tension in SEC admissions policy

October 18, 2016, Just Anti-Corruption

The US Securities and Exchange Commission’s policy of pursuing admissions from defendants in egregious cases is compromised by the threat of parallel criminal charges, lawyers have told Just Anti-Corruption.

SEC’s jurisdiction over foreign executives bolstered by Magyar Telekom judgment

SEC’s jurisdiction over foreign executives bolstered by Magyar Telekom judgment

October 11, 2016, Just Anti-Corruption

Pursuing foreign nationals at the top of the corporate hierarchy is notoriously difficult in Foreign Corrupt Practices Act cases. But a September ruling by a Manhattan judge may have made it easier, in some instances, for the US Securities and Exchange Commission.

Declinations becoming ‘NPA-lite’ under FCPA pilot programme, lawyers say

Declinations becoming ‘NPA-lite’ under FCPA pilot programme, lawyers say

October 04, 2016, Just Anti-Corruption

Companies seeking a declination should factor in that their wrongdoing could be exposed to the public by the US Department of Justice, say lawyers, as the lines between a traditional declination and a non-prosecution agreement blur.

Court partly bars penalties against two Magyar Telekom execs on statute of limitations grounds

Court partly bars penalties against two Magyar Telekom execs on statute of limitations grounds

October 03, 2016, Just Anti-Corruption

A Manhattan federal judge on 30 September also ruled that the US Securities and Exchange Commission has jurisdiction to bring FCPA charges against overseas employees who help prepare falsified SEC filings.

Transcript: SEC press conference call on Och-Ziff FCPA case

Transcript: SEC press conference call on Och-Ziff FCPA case

September 30, 2016, Just Anti-Corruption

Just Anti-Corruption publishes a transcript of the Securities and Exchange Commission's conference call with journalists about the Foreign Corrupt Practices Act administrative proceedings against hedge fund Och-Ziff Capital Management Group.

DOJ orders disgorgement in two FCPA pilot programme declinations

DOJ orders disgorgement in two FCPA pilot programme declinations

September 29, 2016, Just Anti-Corruption

The US Department of Justice on 29 September issued declinations to two companies, imposing disgorgement for the first time under the FCPA pilot programme in the absence of a parallel action by its civil enforcement partner, the Securities and Exchange Commission.

DOJ boosts FCPA unit with three new prosecutors

DOJ boosts FCPA unit with three new prosecutors

September 21, 2016, Just Anti-Corruption

The Foreign Corrupt Practices Act unit of the US Department of Justice’s criminal division fraud section has hired three prosecutors, including a former Jones Day associate based in Brazil.

Special Report: FCPA Counsel Tracker

Special Report: FCPA Counsel Tracker

September 13, 2016, Just Anti-Corruption

Just Anti-Corruption is launching FCPA Counsel Tracker, which details who has been advising companies on DOJ declinations, past settlements and current investigations, as well as who's been taking up monitorships.

DOJ: Recent Supreme Court ruling supports FCPA conspiracy charge against former Alstom exec

DOJ: Recent Supreme Court ruling supports FCPA conspiracy charge against former Alstom exec

September 12, 2016, Just Anti-Corruption

The US Department of Justice has argued it is “normal and regular” to prosecute foreign nationals who commit misconduct abroad by applying conspirator and accomplice liability under US criminal law, in a brief filed 9 September.