- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Jaclyn Jaeger2020-08-18T21:12:00
The Department of Justice last week issued its first FCPA opinion procedure in six years. Experts weigh in on the ruling, the gap between opinions, and more.
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A payment by a U.S.-based company to a third-party intermediary under circumstances that placed an employee’s life and well-being at “significant risk” would not trigger enforcement under the anti-bribery provisions of the FCPA, the Department of Justice stated in an opinion procedure.
The first update to the SEC and Justice Department’s FCPA Resource Guide since it was published in 2012 includes several clarifications intended to benefit chief compliance officers and in-house counsel.
The Department of Justice this month made a few minor adjustments to its Corporate Enforcement Policy that are worth a closer look, as these changes could impact when compliance officers and corporate counsel decide to self-report a potential Foreign Corrupt Practices Act violation.
The U.S. Supreme Court extended the statute of limitations for businesses attempting to challenge some federal regulations, allowing regulated entities a longer timeline to appeal a decision.
The Supreme Court of the United States overturned a long-held precedent in which courts deferred to federal agencies in interpreting complex or ambiguous regulations–a decision that could make thousands of federal regulations more vulnerable to legal challenges.
Financial institutions would be required to conduct more thorough risk assessments on their anti-money laundering/countering the financing of terrorism programs under a new rule proposed by the Treasury Department’s Financial Crimes Enforcement Network.
