Charles Duross

Charles Duross

Morrison & Foerster LLP

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DOJ Is Moving Away From The Halliburton Opinion

The U.S. Department of Justice just issued its most recent Foreign Corrupt Practices Act opinion release, only the second in 2014. The requestor, a publicly traded U.S. consumer products company, sought an opinion as to...more

11/26/2014 - DOJ Enforcement Actions FCPA Jurisdiction Manufacturers Successor Liability Target Company

DOJ’s Second Opinion Release of 2014: Is DOJ Evolving Away from the Halliburton Opinion Standard?

The Department of Justice (“DOJ” or the “Department”) just issued its most recent FCPA Opinion Release, only the second in 2014. The Requestor, a publicly traded U.S. consumer products company, sought an opinion as to whether...more

11/20/2014 - DOJ Due Diligence Enforcement Actions FCPA FCPA Guidance Halliburton Halliburton v Erica P. John Fund Integration Jurisdiction Successor Liability Target Company

Global Procurement Quarterly - Summer/Fall 2014

In This Issue: - Recent Trends in FCPA Enforcement – First Half of 2014 - Ukraine/Russia–Related Sanctions - New Executive Order Places Additional Reporting Obligations on Government Contractors and...more

10/14/2014 - China Emerging Technology Companies Enforcement Actions FCPA Federal Contractors Reporting Requirements Russia Sanctions Suspensions & Debarments Ukraine World Bank

Bribery, Twice Removed

Charles Duross is the head of Morrison & Foerster’s Global Anti-Corruption Practice. He is the former head of the Department of Justice’s Foreign Corrupt Practices Act unit, where he took a leading role in developing and...more

8/22/2014 - Anti-Corruption Bribery Chief Compliance Officers Compliance Corruption FCPA

Consultants Indicted in Japan for Paying Bribes in Vietnam

Following on the heels of Japanese trading company Marubeni’s recent admission that it violated the U.S. Foreign Corrupt Practices Act, again a Japanese company is in the crosshairs of anti-corruption regulators, but this...more

8/14/2014 - Bribery Consultants Corruption Japan White Collar Crimes

Japan Discloses New Efforts to Combat Foreign Bribery, as OECD Steps Up Pressure on Japan to Increase Enforcement

While many people don’t know it, a bribery scandal in Japan in 1976 was part of the motivation for the Foreign Corrupt Practices Act (FCPA), which was signed into law on December 19, 1977. Almost exactly two decades later,...more

7/14/2014 - Bribery Compliance FCPA Foreign Official Japan OECD White Collar Crimes

World Bank Suspension and Debarment Report

On June 26, 2014, the World Bank’s Office of Suspension and Debarment (OSD) released its public report covering sanctions arising from World Bank-financed projects during OSD’s first six years of operation. The report...more

7/2/2014 - Corruption Fraud Information Reports Performance and Accountability Report Project Finance Sanctions Transparency World Bank

Court of Appeals Hands Down Landmark FCPA Ruling Defining the Term “Instrumentality”

Federal appellate court decisions interpreting the Foreign Corrupt Practices Act (FCPA) are rare. Very rare. Indeed, in the statute’s 36-year history there have been barely more than a handful of appellate court decisions...more

5/24/2014 - Anti-Corruption Compliance Criminal Prosecution DOJ FCPA Foreign Official Instrumentality SEC Terra Telecommunications US v Esquenazi

Charles Duross: FCPA reform, DOJ trials and the revolving door

What matters were you particularly proud to have been involved in during your time at the DoJ? I’m proud of all of it but I think there are probably a couple of specific matters that stand out in my mind. The first...more

4/10/2014 - Compliance DOJ Enforcement FCPA Financial Regulatory Reform

Anti-Corruption Developments to Expect in Asia in 2014

Recent anti-corruption enforcement developments in Asia should serve as a call to action for international and domestic companies operating in the region. In light of these developments — which include increased enforcement...more

4/2/2014 - Anti-Corruption Asia Compliance

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