This article originally appeared on Law360 on June 9.

The novel coronavirus and resulting global health pandemic and economic crisis created a perfect storm for bad actors to engage in fraud and financial crimes. Law enforcement’s response to the criminal activity spurred by the pandemic and economic stimulus and relief efforts are still nascent and focusing on low hanging frauds by individuals and small groups.
Continue Reading Another COVID-19 Enforcement Tool: Money Laundering Law

A red sky at morning is the traditional harbinger of ill weather. From our vantage point in Brussels, we’ve scanned the horizon for signs of the future of anti-bribery enforcement activity in Europe. We’ve identified four factors that are starting small, but may build into heavy seas.

In particular, there are signs that companies that sell to governments in Europe may be well advised to shore up compliance procedures so they can remain dry if a wave of anti-corruption sentiment breaks over the public procurement sector.


Continue Reading Shelter from the Coming Storm: Anti-Corruption Compliance in European Public Procurement

I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of time for leisure and family. Indeed, most attempts by the country to preserve la vie Française are idealistic efforts to protect what I see as a beautiful way of life (perhaps excluding some of the Académie Française’s more laughable efforts to provide French alternatives to borrowed English words). And some of the country’s biggest companies represent not only the economic engines of France but also embody national pride in global market power.
Continue Reading BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy

By: Reid Whitten

On December 22, 2011, Ousama Naaman, a former agent for Innospec Inc., was sentenced to serve 30 months in prison and pay a fine of $250,000 following his guilty plea to charges of violating the FCPA and conspiracy to violate the FCPA, among others.  Naaman, a Canadian citizen, was arrested in Germany in July 2009 and extradited to the United States to face prosecution. 
Continue Reading Even the Bagman: Foreign Agent Sentenced to Thirty Month Prison Term for FCPA Violations