News & Analysis as of

Instant Messaging Apps Foreign Corrupt Practices Act (FCPA)

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

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This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

Paul Hastings LLP

More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends

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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

Vinson & Elkins LLP

Updated DOJ Guidance on Devices and Ephemeral Messaging

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On March 3, 2023, the Department of Justice (“DOJ”) issued long-awaited guidelines on how it will evaluate whether companies have implemented appropriate guidance and controls on the use of personal devices and third-party...more

BakerHostetler

DOJ Corporate Criminal Enforcement Updates Shine a Spotlight on Texts and Instant Messaging Applications as Potential Evidence

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In September 2022, the U.S. Department of Justice (DOJ) issued a memo announcing revisions to the DOJ’s corporate criminal enforcement policies and practices....more

Wiley Rein LLP

Corporate Criminal Enforcement Predictions for 2023

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With all eyes turning to 2023, recent Department of Justice (DOJ) corporate enforcement policy changes and clarifications hint at what can be expected from the DOJ in the year ahead. In September, Deputy Attorney General...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2022

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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

Paul Hastings LLP

Ephemeral Messaging at the Office: Avoiding Pitfalls and Establishing Best Practices

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Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more

Eversheds Sutherland (US) LLP

Enforcement appears as messages disappear: The perils of personal and ephemeral messaging

On December 17, 2021, a financial institution agreed to pay $200 million in fines to the Securities and Exchange Commission and Commodities Futures Trading Commission for allowing employees to discuss business on their...more

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