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    Dec. 18, 2024

Fielding for Five Rings: Bribery and Corruption Risk in India’s Sports, Media and Entertainment Sectors

In August 2024, Indian Prime Minister Narendra Modi announced India’s ambition to bid for the 2036 Summer Olympics. As India advances its ambitions on the global stage, the spotlight intensifies on its sports, media and entertainment sectors — sectors integral to India’s cultural fabric and its economic future. For companies operating and intending to operate in these sectors in India, understanding the current landscape of domestic and international anti-bribery and anti-corruption issues in these areas is crucial. This first article in a two-part article series provides insights into the challenges the sports, media and entertainment industries face in India. The second article will outline strategies to promote transparent and ethical practices to ensure a sustainable and compliant future in this field. See “‘Quid Pro Quote’ and Other Corruption Risks in the Sports, Media and Entertainment Industry” (Mar. 30, 2022).

Raytheon’s $950‑Million Settlement: Does It Count As a Win?: Unlocking the Compliance Opportunities in Multiple Monitorships

Raytheon Company (Raytheon) and its parent company, RTX Corporation, recently entered into settlement agreements with several federal agencies with the hefty price tag of $950 million in fines and disgorgement. However, the biggest news was that the companies must retain multiple compliance monitors to ensure that they are following through on the promises they made in the settlements. Imposition of a monitor is a feared outcome for many companies subject to federal investigation as monitors are both expensive and invasive. Yet, they can provide an opportunity: a chance to refresh and elevate a corporate compliance program without much in the way of pushback from money crunchers, naysayers or other internal stakeholders. The first article in this two-part series laid out the many moving pieces that made up the whole of Raytheon’s settlement. This second part shifts focus to the monitorships and the lessons learned from the resolutions for companies in the aerospace and defense industries. See “How to Build a Sustainability Plan After Settling With the DOJ” (Nov. 6, 2024).

Telefónica Venezolana Settlement Highlights the Risks of Operating in Volatile Economies

Telefónica Venezolana C.A., the Venezuelan subsidiary of Spanish telecom group Telefónica S.A., has settled allegations from the DOJ that it paid officials to get preferential access to hard currency, a precious commodity in Venezuela, necessary to keep business operations going. A range of factors fed into the penalty sum, including the company’s remediation efforts, cooperation with investigators and a previous bribery issue with a different Latin American subsidiary. This article summarizes the bribery scheme, the company’s remediation efforts and what lessons other companies should take away. See “Venezuela Presents High Risk for Foreign Companies” (Sep. 27, 2023).

Could Emojis and Video Communications Be the Next Frontier of SEC Scrutiny?

Three years and well over $3 billion in fines into the SEC’s sweep of off-channel communications, the financial services industry is reeling at the intensity of the regulator’s scrutiny. The SEC’s unrelenting efforts are causing heightened concerns and paranoia about the next areas likely to be targeted. According to some experts, those fears are not necessarily unfounded. “The SEC will go as far into the financial services industry as their jurisdiction permits them,” suggested Seward & Kissel partner Michael Watling. Therefore, some investment advisers are exploring whether they need to focus on two areas recently highlighted by FINRA: emojis and video communications. This first article in a two-part series offers an overview of the SEC’s ongoing scrutiny of off-channel communications to date, and contemplates why emojis and video communications may be areas targeted by the Commission and other regulators in the future based on recent comments and legal developments. The second article will identify challenges that emojis and video communications present for advisers attempting to record, retain and monitor those forms of technology, and suggest how advisers can bolster their corresponding compliance efforts. See “Crafting Effective Mobile Device Policies to Satisfy Regulatory Expectations” (May 8, 2024).

McGuireWoods Strengthens White-Collar Practice by Adding Partner Duo in D.C.

McGuireWoods has welcomed two partners, Steven McCool and Julia Coleman, to its government investigations & white collar litigation department in Washington, D.C. Both attorneys join from McCool Law and represent companies and individuals in matters related to the FCPA; export controls; money laundering; and bank, securities, government contracting, mortgage and other accounting fraud. For insights from McGuireWoods, see “As the U.K. Bribery Act Turns Seven, Experts Take Its Pulse” (Jul. 25, 2018).

International Regulatory Partner Joins Troutman Pepper’s D.C. Office

Pete Jeydel has joined Troutman Pepper as a partner to lead the firm’s sanctions and trade controls team, based in Washington, D.C. He arrives from Steptoe.

Most-Read Articles

Spotlight on Trailblazing Women

To mark International Women’s Day 2024, women editors and reporters of ION Analytics interviewed outstanding women in the industries and jurisdictions we cover. In this part, Jill Abitbol, Managing Editor of the Cybersecurity Law Report and Anti-Corruption Report, features notable women in data privacy, cybersecurity, white collar defense, compliance and anti-corruption law, including Christina Montgomery, Leslie Shanklin, Palmina Fava, Alexandra Ross and Lucinda Low. Enjoy reading their inspiring remarks here.

Ion Analytics' Spotlight on Trailblazing Women

In honor of International Women’s Day, some of ION Analytics' editorial teams led by women interviewed notable women in the markets and industries we cover. This part highlights notable women in compliance and hedge fund, data privacy and cybersecurity, and anti-corruption law, including Amii Barnard-Bahn, Abigail Bell, Genna Garver, Jane Horvath, Barbara Li, Amy Mushahwar, Mara Senn and Carol Widger. The interviews are here.

Data, Culture, ESG and Scope Creep with GM's Michael Ortwein

The Anti-Corruption Report spoke with chief compliance officer and assistant general counsel at General Motors, Michael Ortwein, who shared his insights on top-of-mind issues in advance of his participation in ACI's FCPA Conference. 

The full video is here. The associated article is here.

Corporate Compliance and Enforcement Hot Topics With IBM VP Una Dean

The Anti-Corruption Report spoke with IBM's vice president and assistant general counsel of investigations Una Dean, who co-chaired ACI's FCPA conference, about a range of hot compliance topics. 

The video is here

Quick Take on FARA

https://acuris.wistia.com/medias/wmb5vyeq2f

The Anti-Corruption Report discusses the Foreign Agents Registration Act (FARA) in this short video. For our three-part guide to FARA and the new risk environment, see here.

ACR Editor Discusses Using Artificial Intelligence to Support Anti-Corruption Compliance

Senior Editor Megan Zwiebel recently appeared on a podcast with Perkins Coie White Collar & Investigations partners Gina LaMonica and Caryn Trombino, who discussed the use of AI in compliance programs, including trends in AI-based compliance, steps companies can take to utilize AI in their compliance programs, and how regulators view the use of data and AI in compliance programs. Listen to the podcast here.

ACR Q3 Editorial Update

Listen to our Fall Editorial Update for a discussion of recent enforcement actions; enforcement trends and policies; and top-of-mind issues, such as internal investigations and hotlines, all in under 15 minutes. Register here.

ACR and CSLR Spring Update 2020

​​​​The Senior Editors of the Anti-Corruption Report and the Cybersecurity Law Report recently teamed up to present an update on the trends and hot topics in the anti-corruption, cybersecurity and data privacy spaces since the beginning of the year and what the publications will be focusing on in the coming months. A complimentary download of the webinar is available here.

Upcoming Webinar to Explore Best Practices for AML Compliance by Private Fund Managers

Please join our sister product, the Hedge Fund Law Report, on Thursday, May 30, 2019, at 11:00 a.m. EDT, for a complimentary webinar discussing the key components of a robust anti-money laundering program. To register for the webinar, click here.

ACR Webinar: The Art and Science of Transaction Monitoring: A Google Perspective

Transaction monitoring can help a company identify problem areas and assess how well its compliance program is working. Please join the Anti-Corruption Report for a complimentary webinar on May 2, 2019, from 1 p.m. to 2 p.m. EDT, where Senior Editor Megan Zwiebel will interview Google global ethics & compliance senior counsel Therese Lee and forensic program manager Aditya Yerramilli about how Google handles the art and science of transaction monitoring. Registration information is here.

ACR Webinar: Mitigating Risk in Argentina After the Notebooks Scandal

Doing business in a country that is embroiled in a mega-scandal can be treacherous. This is particularly true when the local business community is slow to get on the compliance bandwagon, as has been the case in Argentina while the Notebooks Scandal has been unfolding. Please join the Anti-Corruption Report on April 17, 2019, from 1:00 p.m. to 2:00 p.m. EDT for a complimentary webinar in which Editor-in-Chief Nicole Di Schino will discuss how to mitigate risk in light of the developing scandal with Argentinian attorney Guillermo Jorge, a partner at Bruchou, Fernandez Madero & Lombardi, and Barrick Gold’s Jonathan Drimmer. To register, please click here.