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In her recent speech at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute, Principal Deputy Assistant Attorney General Nicole M. Argentieri discussed the Evaluation of Corporate...more
In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
Assistant Attorney General Kenneth A. Polite, Jr. began his speech with an interesting aside. It is about the clear tie between poverty and corruption. This is why it is important to prosecute corrupt government officials...more
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more
It has been an eventful six months in the world of corporate compliance. In September 2022, Deputy Attorney General (AG) Lisa Monaco introduced major updates to the U.S. Department of Justice’s (DOJ’s) corporate criminal...more
Imagine your company has gone through a Foreign Corrupt Practices Act (FCPA) investigation. As you near the end of the investigative phase and move into the enforcement phase, you tell the government that you have terminated...more