In October 2018, the Benczkowski memorandum was published reconsidering the U.S. Department of Justice’s approach to the use of corporate monitors to ensure that monitorships will not impose unnecessary burdens on businesses. Yet since then, practice shows that 50% of Foreign Corrupt Practices Act (FCPA) corporate resolutions still result in…
The settlement agreement has been signed, hands have been shaken, and what seemed to be an endless string of meetings and update calls with the counsel and the government, has come to the end. But not all companies that reached Foreign Corrupt Practices Act settlements with the U.S. Department of…
On April 26, 2015, a new law requiring companies to have compliance programs came into effect in Ukraine. The law applies to almost all companies participating in public tenders and to state owned enterprises over a certain size. Among other things, it requires companies to appoint a compliance officer with…
On January 25, 2015, a law creating a new anti-corruption bureau entered into force. The Bureau will be empowered to investigate misconduct by high-level public officials. While Ukraine has seen its share of ineffective anti-corruption agencies, this one may be different, for three reasons: The law contains several provisions designed to…