At the 33rd ACI International Conference on the Foreign Corrupt Practices Act ("FCPA"), leading prosecutors and regulators from the U.S. and the UK emphasized the importance of international cooperation, self-disclosure, and a heightened focus on individual responsibility.
Cadwalader attorneys summarized key statements and themes that were covered at the conference in a Cadwalader memorandum. Officials from the Department of Justice ("DOJ"), the SEC and the UK Serious Fraud Office (i) described skyrocketing international law enforcement coordination, (ii) announced "sticks" and "carrots" to encourage self-disclosure and cooperation, and (iii) pledged to hold individuals accountable for anti-corruption violations.
Cadwalader attorneys considered the ways in which Senator Jeff Sessions might shape the Justice Department's approach to white-collar crime.
Cadwalader attorneys examined the first two resolutions reached under the DOJ's new Foreign Corrupt Practices Act Enforcement Plan and Guidance.
GAO issued a report on the collection and use of fines, penalties and forfeitures assessed against financial institutions for their violations of BSA/AML regulations, the Foreign Corrupt Practices Act and U.S. sanctions programs requirements.
Cadwalader attorneys asserted that companies operating in China need to do more to enforce Foreign Corrupt Practices Act practices and procedures. If policies and procedures are "no more than words on paper, they are toothless paper tigers."
The DOJ and the SEC announced one of the largest global Foreign Corrupt Practices Act settlements in history. Under the settlement, a Dutch telecommunications will pay $795 million to resolve allegations that it paid $114 million in bribes to an Uzbek government official to obtain and retain business in the country.