In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
10/18/2023
/ CFTC ,
Compliance ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Electronic Communications ,
Financial Industry Regulatory Authority (FINRA) ,
Guidance Update ,
Instant Messaging Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Workplace Communication
As described in the first White Paper in this series on internal investigations, "Conducting an Effective Internal Investigation—An Overview," corporations are under increased scrutiny by regulators across the globe, and as a...more
Although French companies have made progress in anticorruption compliance over the past two years, the French Anticorruption Agency ("FAA") has found that they still have difficulty implementing certain measures, particularly...more
On October 1, 2020, the new Instruction on the Investigation and Prosecution of Foreign Corruption for the Dutch Public Prosecution Service ("DPPS") entered into force, indicating certain factors that play a role in...more
10/30/2020
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corruption ,
Criminal Liability ,
Criminal Prosecution ,
Ethics ,
Foreign Official ,
New Guidance ,
Penal Code ,
Public Officials ,
Self-Disclosure Requirements ,
White Collar Crimes
Companies should identify and, where appropriate, manage risk associated with gifts and entertainment by incorporating a clear policy into their overall corporate compliance strategy.
On September 11, 2020, the French...more
The French Anti-Corruption Agency ("FAA") report details key statistics relating to the controls the FAA carried out in 2019 and lessons to be drawn from this activity.
On 9 July 2020, the FAA published its 2019 annual...more
7/20/2020
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Cooperation ,
Corruption ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Jurisdictions ,
France ,
Serious Fraud Office (SFO) ,
White Collar Crimes
The Financial Public Prosecutor and the French Anticorruption Agency ("FAA") have recently adopted guidelines on the implementation of the "convention judiciaire d'intérêt public" ("CJIP"), the French version of a deferred...more
8/16/2019
/ Anti-Corruption ,
Blocking Statutes ,
CJIP ,
Compliance ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Enforcement Actions ,
Enforcement Authority ,
France ,
New Guidance ,
Public Prosecutors
The Enforcement Committee of the French Anticorruption Agency ("FAA") handed down its first decision on July 4, 2019. The decision follows the Agency's three-month audit (October to December 2017) of the involved company's...more