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DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

DOJ Releases First FCPA Advisory Opinion in Six Years

On August 14, 2020, the Department of Justice (the “DOJ”) issued its first Foreign Corrupt Practices Act (the “FCPA”) advisory opinion in almost six years....more

DOJ and SEC Publish New FCPA Resource Guide

On the eve of the July 4th holiday, the Criminal Division of the Department of Justice (the “DOJ”) and the Enforcement Division of the Securities and Exchange Commission (the “SEC”) quietly published the second edition of the...more

Two Years Since Sapin II: Is France Now a Player in the Global Anti-Corruption Enforcement Arena?

In December 2016, the French Parliament passed a landmark anti-corruption law, Law No. 2016-1691 on Transparency, Fighting Corruption and Modernising Economic Life (the “Sapin II” or the “Law”), which strengthened the...more

Foreign Corrupt Practices Act 2017 Year-End Update

2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more

ISO 37001: Testing the Ability to Implement a Global Anti-Bribery Standard

A year after a global anti-bribery standard was implemented by the International Standards Organization (“ISO”), a slow trend is emerging among major corporations, such as Microsoft and Wal-Mart, announcing they will seek...more

Multinationals Need to Pay Attention to China's Anti-Corruption Campaign

The People’s Republic of China continues to modify its anti-corruption enforcement regime through its new pilot program and the adoption of recent amendments to its anti-corruption laws. In China, there are two major...more

New French Anti-Corruption Law: Companies Doing Business in France Must Beware

On November 8, 2016, France modernized its anti-corruption enforcement regime and adopted the Law on Transparency, the Fight against Corruption and Modernization of Economic Life (known in France as “Sapin II,” named after...more

Clean Hands, Smart Deals: A primer on complying with foreign anti-bribery laws

With the approaching financial year-end and the consequences of external audits, along with the new and increased risk of individual liability executives face in light of the recent Department of Justice “Yates Memorandum”,...more

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