The Justice Department is wedded to its FCPA Corporate Enforcement Policy (excuse me for the use of “wedded,” we recently celebrated our son’s wedding).  Nonetheless, DOJ has to adjust its Policy in response to experience and feedback.  That is a good thing and one that helps to ensure that the Policy is predictable and consistent in its application. I am convinced that the FCPA Corporate...

Matt Stankiewicz rejoins us for another posting on cryptocurrency compliance. Matt can be reached at [email protected]. Just this month, former CFTC Chairman Timothy G. Massad released a report through the Brookings Institution entitled “It’s Time to Strengthen the Regulation of Crypto-Assets.”  Interestingly enough, Mr. Massad was at the helm of the CFTC during the financial crisis.  He even notes that he “share[s] the desire to...

Webinar: Top 3 Areas for Anti-Corruption Compliance April 11, 2019, 2 PM EST SIGN UP HERE As corruption risks increase, are you aware of the top 3 focus areas for compliance? Thomson Reuters is pleased to offer a webinar conducted by Julie DiMauro, Regulatory Intelligence Expert, and Michael Volkov, CEO at The Volkov Group focused on the top-3 issues for anti-corruption compliance. Global anti-corruption risks...

There is nothing training cannot do. Nothing is above its reach. It can turn bad morals to good; it can destroy bad principles and recreate good ones; it can lift men to ‘angel ship. – Mark Twain I am always struck by how much is written about tone-at-the-top, board commitment to compliance and specific benchmarking of chief compliance officer access and reporting to a corporate...

In a shocking announcement, federal prosecutors announced the arrest and charges against numerous individuals in connection with a nationwide criminal investigation focusing on college entrance exam cheating and admission of students to elite universities as fake athletic recruits.  Athletic coaches from Yale, Stanford, USC, Wake Forest and Georgetown, as well as parents and exam administrators have been implicated. At the center of the scam was...

We spend a lot of time discussing foreign bribery.  The United States has its own bribery problems, depending on the states in which a business operates and the extent to which it relies on government business.  Sometimes our myopic approach ignores significant domestic bribery risks. The FBI has long been at the forefront of the fight against federal and state bribery in the United States. ...

Matt Stankiewicz, Senior Counsel at The Volkov Law Group, rejoins us for an interesting posting on 2019 cryptocurrency trends and regulations. Matt can be contacted at [email protected]. You’ve heard this before, but it still holds true – cryptocurrency regulations are coming.  Everyone knows they’re inevitable, and there has been some trepidation amongst investors that regulations will disrupt innovation and just generally cause a mess within...

The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history.  The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures.  The details of the enforcement action underscore several important trends and enforcement policies.  Let’s review some of the more significant lessons learned and trends. Application of FCPA Corporate Enforcement Policy: MTS was not able...

The MTS bribery scandal in Uzbekistan represents the culmination of several significant FCPA violations involving VimpelCom, Telia Sonera, MTS, and Gulnara Karimova, the notoriously corrupt daughter of the former Uzbek President.  Karimova is perhaps one of the most notorious corrupt offenders in the world.  She has been under house arrest in Uzbekistan since 2014. (Indictment Here). According to MTS’ admissions, MTS and its subsidiaries, Uzdunrobita...