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DOJ Criminal Division Announces Revisions to its Corporate Enforcement Policy

In Short - The Situation: On January 17, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced significant revisions to the Criminal Division's Corporate Enforcement Policy....more

EU Court Limits EU and Schengen Nations' Ability to Enforce Interpol Red Notices

The Situation: On May 12, 2021, the Court of Justice for the European Union ("CJEU") held that European Union ("EU") and Schengen Area member states cannot make an arrest pursuant to an Interpol Red Notice if the person to be...more

Australia-U.S. Cooperation in Criminal Cases

U.S. criminal law has a long reach outside the borders of the United States. Australian companies and individuals whose activities touch on the United States—even without having offices or any physical presence in the United...more

UK Supreme Court Limits Serious Fraud Office's Extraterritorial Powers

The Issue: The UK Supreme Court was asked to decide whether section 2 of the Criminal Justice Act 1987 granted the Serious Fraud Office ("SFO") powers to compel the production of documents held outside the United Kingdom. ...more

FCPA 2020 Year in Review

In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more

FCPA 2019 Year in Review

In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ...more

Evidence Collection in Criminal Investigations: Cross-Border Issues and Corporate Employee Considerations

In this age of heightened international enforcement of corporate crime, it is critical that companies be prepared for the possibility that government authorities will employ a variety of investigative techniques to obtain...more

France Takes Next Step in Anticorruption Enforcement: First "French DPAs" and What Companies Should Know

The Situation: Anticorruption legislation passed by French lawmakers in 2016 authorizes the resolution of a corruption matter by means of a "convention judiciaire d'intérêt public" ("CJIP"), the French version of a deferred...more

French Anti-Corruption Agency Publishes Information Expected from Companies During Agency Inspections

The Situation: The French Anti-Corruption Agency has published the questions and documentation that companies will be expected to answer and provide when inspected by the Agency. The Result: The French Anti-Corruption...more

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