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Strategies For Navigating Compliance Monitorships

The imposition of an independent compliance monitor continues to be a favored tool of the government in resolving corporate enforcement matters. Indeed, in 2022, both the U.S. Department of Justice and the U.S. Securities...more

A Look Ahead into Corporate Enforcement in the Biden Administration

Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more

Extractive Issuer Disclosures - Understanding the SEC's New Rule

On December 16, 2020, the Securities and Exchange Commission (SEC) voted to approve a Final Rule requiring companies to annually disclose information about payments they made to the U.S. government or any foreign government...more

DOJ and SEC Release Second Edition of the FCPA Resource Guide

On July 3, 2020, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) released the second edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (2020 Guide), the first update to...more

FCPA Litigation Update: DOJ Theories on Unit of Prosecution and Agency Tested, to Mixed Results

Two recent rulings in separate foreign bribery cases highlight the continued impact of individual prosecutions on the interpretation of various provisions of the Foreign Corrupt Practices Act (FCPA). In United States v....more

Juniper FCPA Settlement Provides Useful Compliance Reminders

On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...more

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