

Anti-Corruption Global Trends: reasons to be hopeful and reasons to worry
At the end of March, I attended the now traditional OECD Global Anti-Corruption and Integrity Forum (GACIF) in Paris. More than 3000...

Nicola Bonucci
Apr 4, 20241 min read


From Red Flag to Case File: How FCPA cases typically come to light
Question: How do FCPA cases typically come to light? Answer: The U.S. Department of Justice and Securities and Exchange Commission both...

David A. Last
Apr 3, 20242 min read


Self-Reporting of FCPA Issues – Some Thoughts on Current Incentives and Expectations
Self-disclosure. Cooperation. Remediation. Anyone who has planned for an FCPA-related investigation by U.S. agencies knows this mantra...

John E. Davis
Apr 2, 20242 min read


Stericycle, Inc.
On February 27, 2024, Mauricio Gomez Baez, a former Senior Vice President of international waste management company Stericycle, Inc.,...

James Koukios
Mar 28, 20241 min read


A Zero-Tolerance Policy Can Only Go So Far
The anti-corruption enforcement boom took off first in the United States, then globally. In mere decades, a remarkable international...

Alison Taylor
Mar 27, 20242 min read


A European Duty of Care
Following four years of discussions and a few weeks of intense negotiations, the European Council approved, on Friday, 15 March, 2024, a...

Nicola Bonucci
Mar 26, 20242 min read
