The DOJ’s Telefónica Enforcement: Looking for Roaming Charges?
Last week, the U.S. Department of Justice announced that a subsidiary of Spanish company Telefónica S.A. agreed to pay $85.2 million ...
Dave Lee
Nov 15, 20243 min read
Dynamic, Data-Driven, Fully-Integrated – The Formula for Ensuring Effective Anti-Corruption Compliance
Recent policy shifts and guidance from U.S. regulators have underscored the importance of implementing well-designed and effective...
MarÃa González Calvet
Oct 3, 20242 min read
U.S. DOJ Declines to Prosecute Boston Consulting Group After It Admits to Paying Bribes in Angola – Practitioner Takeaways
Last week, Boston Consulting Group (BGC) announced that the U.S. Department of Justice (DOJ) declined to prosecute the firm despite...
Dave Lee
Sep 5, 20242 min read
A Potential Penrose Triangle: Transparency, Privacy, and the Fight Against Corruption
The Penrose Triangle is an impossible figure (or impossible object or undecidable figure): it depicts an object which could not possibly...
Nicola Bonucci
Aug 1, 20242 min read
Whistleblower rewards work. So why isn’t the world embracing them?
Corruption is notoriously difficult to detect. As I describe in the book that I recently published...
Jessica Tillipman
Jun 13, 20244 min read
Individual Liability Continues at a Drip
Despite the DOJ’s repeated emphasis on holding individuals criminally responsible for corporate misconduct, such as the remarks by ...
Gwen Romack
Jun 6, 20242 min read