DOJ announces tough new approach to the investigation and prosecution of corporate officers and employees.
On September 9, in a major change to its approach to the investigation of alleged corporate crime, the US...more
Court rules that the US Department of Justice cannot expand the FCPA’s reach simply by charging non-resident foreign nationals with conspiracy....more
Amarin is an important US district court opinion affirming the importance of the Second Circuit’s Caronia decision and finding that pharmaceutical and medical device companies have a constitutionally protected right to...more
The court’s interpretation complicates the already difficult task providers face in having sufficient time to assess and quantify potential overpayments.
An August 3 decision in United States v. Continuum Health Partners...more
Revisions bring DOJ and SEC guidance in line with FCPA statutory language.
In June, the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) quietly revised its manual, A Resource Guide to the U.S....more
A relator convicted of criminal conduct is precluded from sharing in related FCA recoveries, irrespective of degree of culpability.
On July 16, a US Court of Appeals for the Ninth Circuit panel upheld the dismissal from...more
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
Amendments aim to improve enforcement of Canadian foreign corruption law by expanding jurisdiction, creating a books and records offense, eliminating the facilitation payments exception, redefining "business" and enforcement...more