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The Foreign Extortion Prevention Act: Broadening The Scope Of Bribery Prosecutions?
A bill introduced in the House of Representatives in late July would allow the United States to prosecute foreign officials who take bribes. The "Foreign Extortion Prevention Act" ("FEPA"), introduced by two Democratic and two Republican
United States
10 Sep 2019
OFAC Continues To Demonstrate Greater Interest In Cryptocurrency Regulation And Enforcement
With the widespread arrival of Initial Coin Offerings ("ICOs") over the last several years,1 U.S. authorities have made deliberate progress toward keeping pace with the fast-growing crypto industry.
United States
13 Aug 2019
New DOJ Guidance Reflects An Evolution In The Evaluation Of Corporate Compliance Programs
On April 30, 2019, the DOJ's Criminal Division published an updated Evaluation of Corporate Compliance Programs Guidance Document ("the Guidance") for prosecutors to use in evaluating corporate compliance programs.
United States
17 May 2019
Modern Slavery Compliance For U.S.-Based (And Other) Multinationals: A Review Of Recent Compliance And Disclosure Developments In The United States And Abroad
Modern slavery compliance is becoming a bigger focus at U.S.-based and other multinationals. Compliance continues to evolve at a rapid pace. Over the last several months,
United States
7 May 2019
FCPA Corporate Enforcement Policy Update: DOJ Introduces New Compliance Requirements For Companies Using Instant Messaging Platforms
On March 12, 2019, the United States Department of Justice (the "DOJ") revised key provisions of the FCPA Corporate Enforcement Policy (the "Policy").
United States
2 Apr 2019
Cybersecurity's Developing Role In FCPA Compliance
First, Cronan discussed a company that allegedly aided and abetted fraudulent payments involving its corrupt agents and customers.
United States
18 Jan 2019
Northern District Of Illinois Updates Mandatory Initial Discovery Pilot Project
Beginning last month, the Northern District of Illinois (or the "Court") modified its Mandatory Initial Discovery Pilot Project (the "Pilot Project") in ways that should come as a relief to corporate
United States
17 Jan 2019
DOJ Deputy Attorney General Outlines Key Policy Revisions Focusing On Individual Accountability, Softening Yates Memo
On November 29, 2018, Deputy Attorney General Rod J. Rosenstein delivered remarks at the American Conference Institute's 35th International Conference on the Foreign Corrupt Practices Act.
United States
4 Dec 2018
United Technologies Hit With $13.9 Million Fine For Making Illicit Payments
On September 12, 2018, the United Technologies Corporation reached a $13.9 million resolution with the SEC over allegations that it violated the anti-bribery, books and records, and internal accounting controls provisions ...
United States
20 Sep 2018
Second Circuit Holds That FCPA Does Not Apply To Foreigners Without U.S. Ties
On August 24, 2018, the United States Court of Appeals for the Second Circuit ruled that a non-resident foreign national cannot be charged with conspiracy to violate the Foreign Corrupt Practices Act ...
United States
29 Aug 2018
Podcast: International Risks Facing Latin America Companies
With the rise of anti-corruption enforcement activity and new laws throughout Latin America and the rise in coordinated efforts between U.S. and Latin American authorities, companies in Latin America ...
United States
13 Aug 2018
DOJ Commentary Underscores The Importance Of Pre-Acquisition Diligence
These statements were consistent with the DOJ's continuing efforts to provide clearer guidance and more consistent outcomes in FCPA enforcement.
United States
6 Aug 2018
Podcast: Common Risks And Challenges In Running A Global Ethics & Compliance Program
As global regulations proliferate and become more complex, so too do the challenges of maintaining a high-performing global ethics & compliance program.
United States
20 Jun 2018
Podcast - Risk Management: Impact Of Revised FCPA Policy On International Risk Management Programs
In this podcast, the second in a two-part series, litigation & enforcement partners Mimi Yang and Ryan Rohlfsen continue our analysis of the revised Foreign Corrupt Practices Act (FCPA) Enforcement Policy.
United States
18 May 2018
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
In November 2017, the U.S. Department of Justice announced a revised Foreign Corrupt Practices Act (FCPA) Enforcement Policy that provides significant incentives for corporations to...
United States
9 May 2018
Dun & Bradstreet Agrees To Pay $9 Million To SEC To Settle FCPA Charges, But DOJ Declines To Prosecute Under New Policy
On April 23, 2018, The Dun & Bradstreet Corporation reached a $9 million resolution with the U.S. Securities and Exchange Commission and the U.S. Department of Justice over allegations that Dun & Bradstreet violated the FCPA.
United States
30 Apr 2018
U.S. DOJ's FCPA Corporate Enforcement Policy: Pilot Program Redux
In March 2017, the U.S. Department of Justice extended the 2016 Foreign Corrupt Practices Act pilot program, pending a review of its "utility and efficacy.1
United States
6 Mar 2018
SEC v. Plexcorps — Cyber Unit Enforcement Action Underscores Potential Challenges To Cross-Border Cryptocurrency Enforcement
Following the hype of Bitcoin, regulatory and other concerns surrounding various forms of cryptocurrency and initial coin offerings ("ICOs") have taken center stage.
United States
19 Feb 2018
The Compliance Challenge: Managing Legal & Regulatory Risk (Video)
Ryan Rohlfsen, a Ropes & Gray government enforcement partner, highlights findings from a new report on legal and regulatory risk management, based on a global survey of 300 in-house professionals.
United States
18 Oct 2017
In The Third-Largest FCPA Enforcement Action Ever, Telia Agrees To Pay Almost $1 Billion To Resolve Bribery Inquiry In Uzbekistan; CEO, Senior Executive, And In-House Counsel Also Charged
In the first blockbuster FCPA action of the Trump administration, on September 21, 2017, Swedish telecommunications company Telia agreed to pay $965 million in total penalties to the DOJ and SEC ...
United States
25 Sep 2017
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