Benjamin D. Klein

Benjamin D. Klein

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Senior U.S. Officials Discuss FCPA Enforcement Trends and Activity

Regulators speaking at the American Conference Institute’s 30th International Conference on the Foreign Corrupt Practices Act tout large penalties, enhanced international cooperation, and a renewed focus on individual...more

11/22/2013 - Anti-Corruption Compliance Cross-Border DOJ Enforcement FCPA

Fraudulent Receipts Pose Risks for Multinationals Operating in China

Multinational companies operating in the country should adapt their compliance programs in light of the risk of civil and criminal penalties. Fraudulent official receipts — or "fapiao"(the Chinese word for an official...more

8/12/2013 - China Compliance FCPA Fraud Invoices Multinationals Risk Management UK Bribery Act

The SEC Speaks: Enforcement Panel Discusses 2013 Priorities and Past Successes

Changing SEC leadership defines its priorities for a new era of SEC enforcement. At the annual "The SEC Speaks" conference on February 22 in Washington, D.C., Acting Director George Canellos and other senior officials...more

2/27/2013 - Elisse B. Walter Enforcement FCPA Mary Jo White SEC Whistleblowers

District Court Decision Limits the Extraterritorial Reach of the FCPA

Judge in Siemens case seeks "limiting principle" for the exercise of personal jurisdiction over foreign defendants and concludes that mere support for a bribery scheme by a foreign defendant is insufficient to establish...more

2/25/2013 - Bribery Extraterritoriality Rules FCPA Foreign Defendants Minimum Contacts Personal Jurisdiction SEC Siemens

District Court Reinforces Broad Territorial Reach of the FCPA

Decision in Magyar Telekom case maintains that engaging in unlawful conduct abroad that is "directed toward the United States, even if not principally directed there," may trigger personal jurisdiction....more

2/13/2013 - Bribery Extraterritoriality Rules FCPA Foreign Corporations Foreign Official Magyar Telekom Personal Jurisdiction SEC

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