Archives: FCPA / Anti-Corruption

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2016 FCPA Year in Review

The year 2016 ushered in a flurry of activity in global anti-corruption and US Foreign Corrupt Practices Act (FCPA) enforcement.  After 2015, when the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) brought their lowest number of enforcement actions in a decade, 2016 not only saw the largest number and highest … Continue Reading

World Bank’s Integrity Vice Presidency Releases Annual Integrity Update

On October 7, the World Bank Group (the Bank) Integrity Vice Presidency (INT) released its Annual Update for the 2016 Fiscal Year (the FY2016 Report or the Report).  This Report emphasizes INT’s endeavor to protect Bank-funded procurement projects in the immediately preceding fiscal year, and sets out INT’s current and future policy, investigation, and enforcement … Continue Reading

Canadian Supreme Court Ruling Confirms World Bank Immunities

On April 29, 2016 the Canadian Supreme Court ruled that the Ontario Superior Court of Justice could not compel the World Bank to produce records or require its personnel to testify in court. The case, World Bank Group v. Wallace, challenged the immunities granted to the Bank that cover its archives and employees. Over the … Continue Reading

DOJ Incentivizes FCPA Voluntary Disclosures with Pilot Program

The Department of Justice (DOJ) is incentivizing companies to self-disclose violations of the Foreign Corrupt Practices Act (FCPA). On April 5, the head of DOJ’s Criminal Division, Assistant Attorney General Leslie Caldwell, announced a one-year pilot program intended to encourage voluntary disclosures of corporate wrong-doing. The guidance, entitled “The Fraud Section’s Foreign Corrupt Practices Act … Continue Reading

2015 FCPA Roundup

In 2015, enforcement of the Foreign Corrupt Practices Act (FCPA) continued to evolve as U.S. government agencies focused their investigations and other countries ramped up their own involvement. While enforcement statistics and monetary penalties remained steady, or even lower than previous years, 2015 trends pointed towards a more complex compliance environment going forward, with increasing … Continue Reading

Court Approves First Ever UK Deferred Prosecution Agreement

On November 30, 2015, a UK court approved for the first time ever the suspension of criminal proceedings against a company under terms set out in a deferred prosecution agreement (DPA). In exchange, Standard Bank Plc agreed to comply with various terms, including payments to the Government of Tanzania of $6 million in compensation, disgorgement … Continue Reading