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Internal Investigations FCPA Corporate Enforcement Policy (CEP)

Guidepost Solutions LLC

DOJ Maintains Interest in Bribery in Mexico and Latin America

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape...more

Burr & Forman

In Wake of DOJ’s Emphasis on Corporate Criminal Enforcement, Companies Should Listen Carefully to Whistleblower Complaints

Burr & Forman on

On February 22, 2023, the U.S. Department of Justice (DOJ) announced updated guidance on the Voluntary Self-Disclosure Policy (VSD Policy). The VSD Policy went into effect immediately in every U.S. Attorney’s Office across...more

King & Spalding

DOJ Releases Updated Export Control and Sanctions Voluntary Disclosure Policy

King & Spalding on

On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more

The Volkov Law Group

Fresenius Pays $231 Million to Resolve Long-Standing FCPA Enforcement Action (Part I of III)

The Volkov Law Group on

Fresenius Medical, the largest supplier of dialysis equipment and services agreed to pay $231 million to the Justice Department and the SEC to resolve FCPA violations in 17 countries in Africa, the Middle East and Europe....more

A&O Shearman

DOJ Revises FCPA Corporate Enforcement Policy

A&O Shearman on

On March 8, 2019, the Department of Justice (“DOJ”) released a revised version of its FCPA Corporate Enforcement Policy (the “Policy”), which provides enforcement and practice guidance to DOJ prosecutors and was formally...more

Thomas Fox - Compliance Evangelist

Flame On-Tribute to the Fantastic Four: Part II – Four Issues from the FCPA Corporate Enforcement Policy

Yesterday, I considered four questions which the Department of Justice (DOJ) may ask Goldman Sachs. Today I want to consider what the company must show under the FCPA Corporate Enforcement Policy....more

Vedder Price

DOJ Criminal Division Announces Major Change in Corporate Enforcement Policy

Vedder Price on

On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more

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