The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry.  DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over $1.7 billion in penalties. Companies in the global commodities trading industry should take heed of DOJ’s focus.  Every significant player in the industry, if not under investigation, should audit and review their operations.  Those...

When it comes to FCPA enforcement, the Justice Department’s global focus for many years was on Asian countries, and in particular, China.  This trend, however, has continued, but in the past few years, DOJ has brought a larger percentage of criminal cases against Central and Latin American entities and individuals.  The reason for this focus reflects DOJ’s long-standing and closer working relationships with prosecutors and...

Perhaps it is fitting to end this unusual FCPA enforcement year with another in a series of compliance reminders — the quickest way to experience a bribery scandal is to ignore third-party risks.  This has been a continuing theme this year and Freepoint is yet another example of why managing third-party risks is so important to any anti-bribery compliance program. The relevant facts underlying the...