In a recent Securities & Exchange Commission (“SEC”) investigation, the SEC interviewed three persons who had proffer agreements with the SEC and United States Attorney. In a subsequent SEC enforcement action, a defendant...more
- Confidential Witnesses Motion to Compel SEC Work Product Privilege
Dr. Harkonen was the CEO of InterMune, Inc, a pharmaceutical company that developed, marketed and sold drugs for lung and liver diseases, including Actimmune. In 2002, the FDA had approved Actimmune to treat only two...more
- Criminal Prosecution Cruel & Unusual Punishment Double Jeopardy Eighth Amendment Exclusion from Government Programs False Press Release FDA Fifth Amendment HHS Misbranding Pharmaceutical Prescription Drugs
At last! We now have official guidance in one place from the United States Department of Justice and the Securities and Exchange Commission regarding the Foreign Corrupt Practices Act (“FCPA”). A lengthy memorandum was...more
- Compliance DOJ FCPA FCPA Resource Guide SEC
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