BriberyMatters
Nov 7, 20242 min read
The FCPA Files: What Can We Learn From Old Cases?
The FCPA will turn fifty in a few years, giving rise to the inevitable host of celebrations and retrospectives. But we don’t need to wait...
Lee Nelson
Oct 24, 20245 min read
A Tough Row: The Challenges of Implementing an ESG Program
Companies face several challenges when implementing Environmental, Social, and Governance (ESG) programs. These can vary by region but...
Dave Lee
Oct 22, 20242 min read
When the Bad Guys Spill the Beans (and You’re the One Who Trips)
Sometimes, there is just no honor amongst thieves.
While it is always risky to give or authorize bribes, that risk...
Dave Lee
Sep 24, 20242 min read
No Sex Please, We’re the SEC
Earlier this month, Deere & Company agreed with the SEC to disgorge about $4.3 million in profits and pay roughly $5.4 million in fines ...
Tom Firestone
Sep 17, 20244 min read
Are the Menendez and Cuellar FARA Charges Unconstitutional?
One of the most significant anti-corruption developments of 2024 has been the use of a previously little used statute, 18 USC 219, to...
Dave Lee
Sep 5, 20242 min read
U.S. DOJ Declines to Prosecute Boston Consulting Group After It Admits to Paying Bribes in Angola – Practitioner Takeaways
Last week, Boston Consulting Group (BGC) announced that the U.S. Department of Justice (DOJ) declined to prosecute the firm despite...