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Beyond the Checklist: Seven Keys to Effective Trade Due Diligence

Anti-corruption due diligence can be vexing even in the best of conditions; it is often made more complicated by time and business pressures that arise in the context of a merger or acquisition or an urgent sales opportunity....more

10/15/2014 - Anti-Corruption DOJ Due Diligence FCPA SEC

Tryin’ to Make a Dollar out of Fifteen Cents: The Diebold FCPA Settlement Explains What Officials Did on Their Vacation

Vacation is great, but it can involve a great deal of planning. And, paradoxically, leisure travel can involve more planning than traveling for business. That travel-related work stands out as a centerpiece of the October...more

11/15/2013 - Bribery Deferred Prosecution Agreements Diebold Inc DOJ Enforcement Actions FCPA SEC

Still Standing: U.S. Court Upholds SEC Conflicts Minerals Rule

In a July 23, 2013 opinion, the U.S. District Court for the District of Columbia upheld the SEC’s rule requiring disclosure of companies’ use of conflict minerals originating in and around the Democratic Republic of the Congo...more

8/8/2013 - Africa Conflicts of Interest Dodd-Frank FCPA Minerals SEC

A Rising Voice on FCPA Compliance: The Court

One FCPA compliance topic we are often asked about by clients is how government investigations start. The U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have developed a number of mechanisms...more

6/11/2013 - Compliance DOJ FCPA IBM Investigations SEC

No Knowledge, but Hints of Omissions in the Allianz FCPA Settlement

On December 17, 2012, the Securities and Exchange Commission (“SEC”) announced a settlement under the U.S. Foreign Corrupt Practices Act (“FCPA”) with Allianz SE (“Allianz”), the insurance company based in Germany, resulting...more

1/10/2013 - Allianz Books & Records Bribery Compliance Disgorgement FCPA FCPA Resource Guide Penalties SEC

What’s Not in the New FCPA Resource Guide, or Why Doing Your FCPA Homework is Still a Good Idea

Notwithstanding our overall approval of the FCPA Resource Guide (the Guide) issued by the Department of Justice (DOJ) and Securities & Exchange Commission (SEC) earlier this month, we are certainly not above a bit of...more

12/6/2012 - Compliance DOJ FCPA FCPA Resource Guide SEC

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