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National Security › FCPA Corporate Enforcement Policy (CEP) › Department of Justice (DOJ)

The Volkov Law Group

Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls...

The Volkov Law Group on

A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a number of significant indicators of a...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Its Approach to Encourage Voluntary Self-Disclosures of Export Control and Sanctions Violations

Orrick, Herrington & Sutcliffe LLP on

On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more

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