A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you. I know I am scratching my head trying to make sense of the whole picture here. There are a number of significant indicators of a change in DOJ’s tack, along...
When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes. With lots of fanfare, DOJ implemented a new...
Life is always filled with surprises. Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South Africa, and Indonesia. The...
Natalie Druckmann, Vice President at Certa, joins Michael Volkov to discuss third-party risk management and the use of advanced artificial intelligence to implement effective risk mitigation strategies. Natalie sets the strategy for Certa’s expansion into the...
Perhaps it is fitting to end this unusual FCPA enforcement year with another in a series of compliance reminders — the quickest way to experience a bribery scandal is to ignore third-party risks. This has been a continuing theme this year and Freepoint is yet...
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