MyComplianceOffice Blog

When looking at the Goldman Sachs’ $3.3 billion settlement and analyzing other similar cases where FCPA applied penalties and disgorgement, we see common failures in financial institutions to maintain internal controls. But what can we learn from the top 10 FCPA fines?

Last year, two executives of Herbalife Ltd. were charged after spending $25 million on entertainment and gifts for Chinese officials in 10 years period, to facilitate the company operations in some regions in China.

Professional football (or Soccer if you’re an American) club Manchester United plc has embarked on an impressive international expansion of its fan base the past several decades. The club currently claims 1.1 billion followers worldwide and is valued at $3.9 billion USD with a revenue of $770 million last year.  

The roll-out of China’s social credit system (SCS) is expected to be nearly complete by 2020. While many news stories have focused on the SCS’ scoring of individuals in China, SCS also applies to companies operating in the country and may impact how they approach anti-corruption compliance.  

The month of June ended what has been one of the most active half-years in Foreign Corrupt Practices Act (FCPA) enforcement ever according to Thomas Fox. The attorney recently covered the subject in a JD Supra blog, citing many high-profile cases in 2019 along with the Department of Justice’s (DOJ’s) revised guidance on evaluating corporate compliance programs.