Beth Forsythe

Beth Forsythe

Dorsey & Whitney LLP

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DOJ, SEC Change “Cooperation Credit” Process, Add Resources to Fight Corruption

During recent speeches Deputy Attorney General Sally Yates and SEC Enforcement Division head Andrew Ceresney announced changes to the processes the DOJ and the SEC will use to decide if a company will receive “cooperation...more

11/19/2015 - Compliance Cooperation Initiative DOJ FCPA SEC

Dorsey Anti-Corruption Digest - October 2015

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

11/2/2015 - Bribery Bristol-Myers Squibb Broken Windows China Corporate Officers Corruption DOJ Enforcement Actions FCPA Government Investigations Hitachi Ireland SEC Siemens Whistleblower Protection Policies Yates Memorandum

Seventh Circuit Rejects Implied Certification Theory of FCA Liability

Deepening a circuit split, the Seventh Circuit has joined the Fifth Circuit in rejecting the implied false certification theory of liability under the FCA. United States v. Sanford-Brown, Ltd., No. 14-2506 (7th Cir., June 8,...more

7/7/2015 - Department of Education Dismissals False Claims Act (FCA) False-Certification of Conformance For Profit Colleges Program Participation Agreements (PPAs) Relators Subsidies Summary Judgment

SEC Fines KBR $130,000 for Using Employee Confidentiality Agreement that Violates Dodd-Frank Whistleblower Protections

The Securities and Exchange Commission (“SEC”) has brought its first-ever enforcement action against a company for using language in confidentiality agreements that prohibits employees from speaking with the SEC without prior...more

4/3/2015 - Confidentiality Agreements Enforcement Actions Internal Investigations KBR (formerly Kellogg Brown & Root) SEC Securities Exchange Act Whistleblower Protection Policies Whistleblowers

D.C. Circuit grants petition for mandamus and strongly reaffirms attorney-client privilege for internal investigations

The attorney-client privilege has long protected attorney-client communications made during the course of an internal investigation. Upjohn Co. v. United States, 449 U.S. 383 (1983). Of course, the privilege encourages “full...more

7/9/2014 - Attorney-Client Privilege Internal Investigations Investigations Upjohn Warnings Writ of Mandamus

Anti-Corruption Digest - April 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

4/18/2014 - Anti-Corruption Chief Compliance Officers Compliance Corruption Enforcement Enforcement Actions

Anti-Corruption Digest - March 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

3/28/2014 - Anti-Corruption Chief Compliance Officers Compliance Corporate Counsel Corruption FCPA

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