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