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Foreign Corrupt Practices Act Enforcement In The Energy Sector
The year 2018 marked a year of active Foreign Corrupt Practices Act ("FCPA") enforcement, with a significant focus on the energy sector.
United States
11 Mar 2019
Global Anti-Bribery Year-In-Review: 2018 Developments And Predictions For 2019
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year—2018 was yet again an active year for FCPA enforcement.
United States
21 Jan 2019
Second Circuit Limits Government's Ability To Prosecute Foreign Persons And Companies For Conspiracy To Violate The FCPA
On August 24, 2018, the United States Court of Appeals for the Second Circuit issued a significant ruling regarding the reach of the FCPA over foreign companies and individuals in United States v. Hoskins, No. 16-CR-1010.
United States
29 Aug 2018
SEC Settles Enforcement Action Against Beam Suntory for Improper Payments by Its Foreign Subsidiary
On July 2, 2018, the Securities and Exchange Commission (Commission or SEC) settled an enforcement action against Beam Suntory Inc. (Beam), a worldwide beverage maker and distributor, over alleged violations of the Foreign Corrupt Practices Act (FCPA) related to improper payments by its Indian subsidiary, Beam Global Spirits & Wine (India) Private Limited (Beam India).
United States
16 Jul 2018
Global Anti-Bribery Year-In-Review: 2017 Developments And Predictions For 2018
This past year marked the 40th anniversary of the FCPA. Since its enactment in 1977, the DOJ has brought approximately 300 FCPA enforcement actions, while the SEC has brought approximately 200 cases.
United States
15 Jan 2018
Global Magnitsky Sanctions Target Human Rights Abusers And Government Corruption Around the World
On December 20, 2017, President Trump issued a new Executive Order (EO) targeting corruption and human rights abuses around the world.
United States
28 Dec 2017
DOJ Announces New FCPA Corporate Enforcement Policy
Today, "[d]ue to the unique issues presented in FCPA matters," Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys' Manual.
United States
30 Nov 2017
DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act (FCPA) enforcement, ..
United States
11 Apr 2016
Busy Q1 Yields Several Significant FCPA Resolutions
Recent actions announced by the DOJ and SEC during the first quarter of 2016 suggest that this year may be a significant one for FCPA enforcement.
United States
30 Mar 2016
Global Anti-Bribery Year-In-Review: 2015 Developments And Predictions For 2016
Among other significant developments, 2015 saw the U.S. Department of Justice (the "DOJ" or the "Department") document a policy priority of holding individuals accountable for corporate wrongdoing.
United States
3 Feb 2016
Federal Judge Rejects DOJ's Theory Of FCPA Accomplice Liability
On August 13, 2015, a US district judge dismissed a charge seeking to hold a defendant criminally liable for conspiracy to violate the Foreign Corrupt Practices Act (FCPA) if he is not a principal or agent of a US domestic concern and did not physically enter US territory.
United States
3 Sep 2015
Global Anti-Bribery Year-in-Review: 2014 Developments and Predictions for 2015
The year 2014 witnessed several notable developments in the enforcement of the Foreign Corrupt Practices Act (FCPA).
28 Jan 2015
Eleventh Circuit Adopts Broad Definition Of Government "Instrumentality" Under FCPA
The Eleventh Circuit affirmed a broad definition of "instrumentality" of a foreign government, as the term is used in the Foreign Corrupt Practices Act.
United States
27 May 2014
2014 M&A Report
Global M&A deal volume declined for the second consecutive year in 2013.
United States
15 May 2014
FCPA Considerations In M&A Transactions
Below is an excerpt from WilmerHale's 2014 M&A Report, which was released on May 6, 2014. This excerpt summarizes the FCPA risks for purchasers and sellers in M&A transactions and suggests affirmative steps companies can take to manage those risks both pre- and post-closing.
United States
15 May 2014
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