MyComplianceOffice Blog

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.  

Attorney Thomas Fox cannot believe how history is repeating itself with new bribery and corruption charges in China’s healthcare industry. Fox breaks down what happened, identifies the different types of bribery schemes that occurred, and provides red flags organizations should be looking for to prevent Foreign Corrupt Practices Act (FCPA) violations in a multi-part blog series.  

Earlier this year, the U.S. Commodity Futures Trading Commission (CFTC) announced for the first time ever, the regulatory body is cracking down on foreign corruption that impacts U.S. commodity and derivatives markets. The regulator also recently issued an advisory to would-be corporate whistleblowers that they could be financially rewarded for their actions, signaling stepped up enforcement actions.  

The U.S. Supreme Court recently held protections in the International Organizations Immunities Act of 1945 against civil lawsuits in U.S. courts were not absolute. Instead, immunity granted to international organizations, including Multilateral Development Banks (MDBs), is no greater than that enjoyed by foreign governments under the Foreign Sovereign Immunities Act (FSIA).  

A 2019 study by Strategy&, the strategy consulting arm of PwC, found for the first time ever, more CEOs were forced out of their organizations for ethical lapses than for poor financial performance or conflicts with their Board.