The SEC has been racking up several FCPA enforcement actions.  DOJ appears to be declining many of these cases. The division of enforcement appeared to follow a pattern – on larger cases with more pervasive violations, DOJ and the SEC would each bring an enforcement action; while on relatively “smaller” cases, the SEC would bring a case and the DOJ would decline to prosecute. This...

Third-party risk management is a favorite topic for compliance professionals.  And for good reason.  Third parties create significant risks.  To state the obvious, companies have less control over third parties than employees. But for many reasons companies engage third parties as a more effective solution than hiring employees.  In this situation, risk multiplies exponentially. The third-party risk issue, however, has multiplied exponentially for a number...