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DOJ Updates Monitor Selection Policy

Key Takeaways- •On March 1, 2023, the Assistant Attorney General (“AAG”) for the Criminal Division of the U.S. Department of Justice (“DOJ”), Kenneth A. Polite, Jr., issued a revised memorandum on the imposition and...more

Top 10 International Anti-Corruption Developments for November 2021

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more

Top 10 International Anti-Corruption Developments For June 2020

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

DOJ Provides New Guidance On Corporate Compliance Programs

On June 1, 2020, the U.S. Department of Justice (“DOJ”) published a revised version of its guidance on the “Evaluation of Corporate Compliance Programs” (the “June 2020 Guidance”). Like its predecessors in February 2017 and...more

DOJ Revises Guidance on Evaluation of Corporate Compliance Programs

On April 30, 2019, the Assistant Attorney General (AAG) for the U.S. Department of Justice’s Criminal Division, Brian Benczkowski, announced the release of an updated version of the “Evaluation of Corporate Compliance...more

How to Comply with the Revised Ephemeral-Messaging Provision in the FCPA’s Corporate Enforcement Policy

In early March 2019, the Department of Justice (DOJ) revised its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy (the Policy). First announced in November 2017, the Policy is designed to encourage companies...more

Top 10 International Anti-Corruption Developments for February 2019

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more

DOJ Announces Revised FCPA Corporate Enforcement Policy - March 2019

On March 8, 2019, DOJ announced that it had made revisions to its November 2017 FCPA Corporate Enforcement Policy (“the Policy”). The revised Policy includes a number of changes, but most notably softens DOJ’s prohibition on...more

Top 10 International Anti-Corruption Developments for September 2018

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Top Ten International Anti-Corruption Developments for November 2017

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Top Ten International Anti-Corruption Developments for April 2017

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Top Ten International Anti-Corruption Developments for December 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

DOJ's New FCPA Pilot Program Will Have Only Marginal Impact

On April 5, 2016, Assistant Attorney General Leslie Caldwell, who heads the Criminal Division of the U.S. Department of Justice, announced a new “FCPA pilot program” designed to motivate companies to voluntarily self-disclose...more

Narrow Reading Of HSR Investment-Only Exemption Continues

On April 4, 2016, the U.S. Department of Justice filed a civil antitrust lawsuit against activist investor ValueAct Capital. The DOJ asserts that ValueAct improperly relied on the “investment only” exemption to the...more

DOJ Announces New FCPA Pilot Program to Encourage Self-Reporting

On April 5, 2016, Assistant Attorney General Leslie Caldwell, who heads the Criminal Division of the Department of Justice (DOJ), announced a new “FCPA pilot program” designed to motivate companies to voluntarily selfdisclose...more

DOJ Suit Against Activist Investor Highlights Narrow Interpretation of HSR “Investment Only” Exemption

On April 4, 2016, the U.S. Department of Justice (DOJ) filed a civil antitrust lawsuit against activist investor ValueAct Capital (“ValueAct”). DOJ asserts that ValueAct improperly relied on the “investment only” exemption to...more

Lessons from DOJ’s FCPA Resolution with PTC China: No Partial Self-Disclosure Credit

In 2015, the Department of Justice (DOJ) made more news for the corporate Foreign Corrupt Practices Act (FCPA) cases that it did not bring than for the two that it did bring: Nine times last year, DOJ declined to join...more

Recent FTC Action Underscores Narrow Interpretation of HSR “Investment-Only” Exemption

On August 24, 2015, the Federal Trade Commission (“FTC” or the “Commission”) filed a proposed settlement in federal court regarding alleged violations by Third Point LLC (“Third Point”) of the premerger reporting laws related...more

Canada’s New Extractive Sector Transparency Measures Act and its Implications for Companies Subject to the U.S. Foreign Corrupt...

On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA” or “the Act”) came into force. Approved in December 2014, but not in force until this month, the Act requires companies in the extractive sector...more

Canada Anti-Corruption Law May Affect FCPA Enforcement

On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA”) came into force. Approved in December 2014, but not in force until this month, the act requires companies in the extractive sector to report...more

Heightened Supervision of Branch Offices — Tips for the Coming Year

In recent years, the Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have heightened their expectations of what constitutes a “comprehensive” branch self-inspection program. Firms...more

The Results Are In: Investors Favor Additional Regulatory Protection

On November 6, 2014, FINRA released results from a survey of U.S. investors measuring the demand for additional regulatory protections. The survey polled 1,000 adults and revealed that an overwhelming majority felt that it...more

The More Things Change, the More They Stay the Same - Key Takeaways from the FTC’s “Updated” Fred Meyer Guides

THE FTC ISSUES AMENDED FRED MEYER GUIDES - On September 24, 2014, the Federal Trade Commission (FTC) approved final amendments to the Fred Meyer Guides (“Guides”). The Guides are intended to help businesses comply with...more

New FINRA Supervision Rules Impact Broker-Dealers’ Insider Trading Procedures and Supervisory Controls

Financial Industry Regulatory Authority (FINRA) rules require member firms to establish and maintain a system of written procedures to supervise the activities of its members. On December 23, 2013, the SEC approved new FINRA...more

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