GIR April 2017

Pages: 48

ISBN: 2055-0502



  • £100.00

In this edition, GIR asks: have we reached Peak Penalty?

While our analysis shows that the number of enforcement actions is on the rise, the total level of associated penalties has dropped from a high of US$65 billion in 2014 to US$36 billion in 2016. In this issue, we take a look behind the headline figures and ask whether we’re likely to see such sizeable enforcement actions in future.

GIR also speaks to lawyers who questioned the value of self-reporting in the wake of Rolls-Royce’s DPA, after the company obtained the settlement without coming forward to the authorities.

Elsewhere, we provide write-ups of 3 conferences: GIR London, ABA Miami, and the OECD’s Global Anti-Corruption and Integrity Forum in Paris. 

In this issue: 

  • GIR’s Enforcement Scorecard
  • Interview: Boyd Johnson and Stephen Pollard (Wilmer Hale)
  • GIR Live DC writeup: 
    • Data leaks and the DOJ pilot programme
    • UK/US conflicts, deleting documents and handling stolen information
    • VimpelCom, Karimova and the importance of international cooperation
    • Dutch Vimpelcom prosecutor: if US says it has jurisdiction, we don’t argue
    • New criminal division deputy stresses ‘continuity’ in FCPA enforcement
    • Compliance counsel has been “very helpful” to fraud section, McFadden says
  • OECD Paris Conference:
    • Nigeria VP calls for inclusion of developing countries in drafting anti-corruption rules
    • French DPAs could leave companies exposed
    • SFO prosecutor calls for “expectation management” when calculating loss in bribery cases
  • Rolls-Royce DPA:
    • David Green: Rolls-Royce deserved DPA despite not self-reporting
    • Self-reporting after Rolls-Royce: is it worth it?
  • ABA Miami Conference: 
    • Beneficial ownership under the spotlight in DOJ investigations
    • ZTE used lawyers as “a mouthpiece to lie”
    • DOJ criminal division deputy: we’re good at cross-pollinating across sections
    • FCPA pilot programme will continue past April, says acting criminal division chief
    • DOJ offi cial: FCPA pilot programme may dissuade some companies from self-reporting
    • GCs welcome new compliance guidance, but question FCPA pilot programme
    • Companies missing SEC message on stifling whistleblowers
  • UK money laundering regime: Money laundering risks for non-regulated businesses
  • People News

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