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Foreign Corrupt Practices Act (FCPA) White Collar Crimes Criminal Liability

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

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There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

Holland & Knight LLP

"Call Us Before We Call You": SDNY Announces Pilot Whistleblower Program

Holland & Knight LLP on

The U.S. Attorney's Office for the Southern District of New York (SDNY) on Jan. 10, 2024, announced a Whistleblower Pilot Program (Program) that it is presenting as another "tool in [the SDNY's] toolkit" that could unearth...more

Orrick, Herrington & Sutcliffe LLP

DOJ revises corporate enforcement policy applicable to all criminal matters including FCPA cases

On January 17, Assistant Attorney General Kenneth A. Polite, Jr. delivered remarks at Georgetown University Law Center, during which he announced changes to the DOJ’s Criminal Division Corporate Enforcement and Voluntary...more

The Volkov Law Group

Prosecutors Embrace Criminal AML Charges in Corruption Cases

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Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants.  Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

Jenner & Block on

Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

K&L Gates LLP

Voluntary Disclosure: Newsflash – October 2020

K&L Gates LLP on

In this episode, we examine how two criminal defendants are aiming to leverage parallel FCPA investigations by the SEC and the DOJ to build their defense. We’ll also offer our thoughts on the SEC’s new (and improved?)...more

Cozen O'Connor

Court Reverses Foreign National’s FCPA Conviction, Setting a High Bar to Establish an Agency Relationship

Cozen O'Connor on

A ruling issued on Wednesday, February 26 by a Connecticut federal court details the type of control necessary to find that a foreign national acted as an agent of a U.S. domestic concern for purposes of falling within the...more

The Volkov Law Group

Wells Fargo Settles With Justice Department for $3 Billion

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This year, 2020, has been an enforcement year opening with billion-dollar settlements: first, Airbus settled FCPA charges for $4 billion, and now Wells Fargo for $3 billion.  What a start to an enforcement year!...more

Robinson+Cole Manufacturing Law Blog

Conviction of Foreign Employee Reinforces Broad Geographic Reach of FCPA

Last week, a jury found a former executive of a French multinational company guilty of violating the Foreign Corrupt Practices Act, money laundering, and conspiracy in connection with alleged bribery in Indonesia....more

Foodman CPAs & Advisors

Did you know that there is FCPA Individual Compliance Responsibility?

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The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It also requires companies whose securities are listed in the US to make and keep...more

Holland & Knight LLP

“Yates Memo” Edited to Grant Prosecutors More Flexibility in Civil Cases

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On Sept. 9, 2015, then-Deputy Attorney General Sally Yates issued a memo requiring federal prosecutors to investigate any individuals responsible for illegal corporate conduct before settling a case. This applied to both...more

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