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DOJ Emphasizes Data-Driven Approach to Monitoring and Importance of Culture in Latest Adjustments to Corporate Compliance Program...

I. INTRODUCTION - On 1 June 2020, the Criminal Division of the U.S. Department of Justice (DOJ) updated a critical guidance document, the “Evaluation of Corporate Compliance Programs” memorandum (“Guidance”), providing...more

DOJ Revises Corporate Compliance Guidance Calling Attention to Three Areas Where Most Companies Fall Short: Risk Assessments,...

On April 30, 2019, the U.S. Department of Justice (“DOJ”) Criminal Division revised its Evaluation of Corporate Compliance Programs Guidance Document (the “2019 Guidance”) to assist prosecutors in evaluating the effectiveness...more

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more

Russia Amends Anti-Corruption Law to Require Affirmative Anti-Corruption Compliance Measures

On January 1, 2013, Russia implemented an amendment to its anti-corruption laws that appears to go beyond the reach of both the U.S. Foreign Corrupt Practices Act (“FCPA”) and the U.K. Bribery Act (“UKBA”) to the extent it...more

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