George J. Terwilliger III

George J. Terwilliger III

Morgan Lewis

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D.C. Circuit Protects Attorney-Client Privilege in Internal Corporate Investigations

The appellate court clarifies that internal corporate investigations are subject to the attorney-client privilege where one of the significant purposes of the investigation is to secure legal advice for the company....more

7/7/2014 - Attorney-Client Privilege Compliance False Claims Act Internal Investigations Kellogg Brown & Root Work-Product Doctrine

Federal Appeals Court Defines “Instrumentality” Under FCPA

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

5/21/2014 - Appeals Controlled Foreign Corporations DOJ FCPA Foreign Official Instrumentality SEC Terra Telecommunications

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

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

Canadian Government Announces Proposed Amendments to Anticorruption Law

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

2/11/2013 - Anti-Corruption Books & Records Bribery CFPOA Corruption Facilitation Payments Griffiths Energy International Jurisdiction

Lanny Breuer Touts Robust, Transparent FCPA Enforcement

Assistant Attorney General Breuer highlights transparency, global trends, and the benefits of robust compliance programs at the American Conference Institute's 28th National Conference on the Foreign Corrupt Practices Act....more

11/26/2012 - Compliance DOJ FCPA SEC

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