Federal appeals court provides a two-step “control” and “function” analysis for determining whether an entity qualifies as an “instrumentality” under the Foreign Corrupt Practices Act.
On May 16, the U.S. Court of...more
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
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
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
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
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