The Biden Administration announced a new, comprehensive anti-corruption program, the United States Strategy on Countering Corruption. The new anti-corruption policy is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern.  After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The Biden Administration released the new United States Strategy...

Alex Cotoia, Regulatory Manager and Compliance Consultant, rejoins us for a blog post of the SEC’s adoption of foreign issuer disclosure rules. Alex can be reached at [email protected]. On December 3, 2021, the U.S. Securities and Exchange Commission (“SEC”) announced the adoption of a final rule that fully implements the requirements of the Holding Foreign Companies Accountable Act (“HFCAA”) enacted by the Congress and signed...

When: December 15, 2021 Time: 2 pm to 3:30 pm EST Sign Up HERE Over the past several years the Department of Justice has periodically issued material updates to guidelines related to compliance programs and enforcement.  The US Chamber of Commerce Institute for Legal Reform has underwritten an important and timely survey of ethics & compliance officers by ECI related to how they are interpreting and...

While we wait for the coming FCPA enforcement storm, DOJ and the SEC have quietly continued to rack up and resolve several enforcement actions.  Here is short and sweet review of many of these actions: Luis Enrique Martinelli, son of the former Panama President, was recently presented in federal court in Brooklyn after the U.S. finally secured his extradition from Guatemala.  Luis Enrique Martinelli sought...

FCPA practitioners, In-house counsel and compliance officers, and yes, even the FCPA Paparazzi, have been patient enough. As the saying goes, talk is cheap.  It is action that counts. We have written often enough about the coming storm – the Biden Administration’s long-anticipated ramp up of white collar enforcement, and FCPA actions in particular.  The groundwork was set – the National Security Memorandum raising the...

On November 12, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 14046, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia, issued sanctions against four entities and two individuals as part of a new sanctions program in Ethiopia. OFAC issued the  sanctions is in response to humanitarian and human rights...