Anti-Corruption Compliance Program Audits
How to Monitor, Audit and Improve Your Anti Corruption Compliance Program
Antitrust Enforcement and Compliance Programs
Anti-Corruption Due Diligence Practical Steps to Protect Your Company from Third Party Risks
A Moment of Simple Justice - Ferguson
FCPA Compliance Programs A Review of Best Practices
Fine Tuning Your Anti Corruption Compliance Program
Creating an Integrated Due Diligence System - Screening to Audits
A Moment of Simple Justice - Revenge Porn
Third Party Due Diligence When is Enough, Enough?
An FCPA Review: A Look Back at 2013 and Trends for 2014
Anti Kickback and Stark Law Enforcement and Compliance Issues
Conducting Interviews in an Internal Investigation 2 13 14, 9 03 AM
A Moment of Simple Justice: Legal Weed
Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM
Internal Investigations: Soup to Nuts (March 13, 2014)
How Can You Better Protect Yourself with the Escalating Trend of FCPA Enforcement?
The Role of a Chief Compliance Officer: Navigating the Compliance Landscape (March 18, 2014)
Keeping Your Due Diligence System Manageable March 31, 2014
Tailoring Your Anti Corruption Program to a Risk Assessment
Sentencing Commission Requests and Receives Comments on Price Fixing Penalty Revisions -
The U.S. Sentencing Commission is currently seeking public comments on sentencing for price fixing, bid rigging and market...more
China’s MOFCOM Blocks ‘P3 Alliance’ Despite EU, U.S. Non-Opposition -
On June 17, 2014, China’s Ministry of Commerce, China’s competition regulator, prohibited the proposed “P3 Alliance” that would have combined the...more
The FCPA has broad extraterritorial reach. Everyone knows that and understands how foreign conduct can be prosecuted in the United States courts.
FCPA violators, however, are learning about the long-arm of the law and...more
In This Issue:
- COURT DENIES BLUES’ MOTION TO DISMISS IN RE BLUE CROSS BLUE SHIELD ANTITRUST LITIGATION (MDL 2406):
On June 18, United States District Court Judge David Proctor (Northern District of Alabama)...more
Steady as clockwork, auto parts investigations around the globe are continuing. These investigations have exposed wide-ranging price fixing conspiracies. Prosecutors rely on well-organized global enforcement cooperation,...more
In this issue:
- The U.S. DOJ Secures Two Extraditions of Foreign Nationals on Antitrust Charges: Who Is Next?
- U.S. Circuit Courts Limit Reach of Sherman Act Against Asian Cartel
- Mark Rosman, Partner...more
It was the week before Chinese New Year. The financial year had ended weeks earlier and unpaid invoices had made a dent in the annual performance of the small family business. For months, the foreign husband, a co-owner of...more
In Part I of my review of the 11th Circuit Court of Appeals decision in the Esquenazi case, I reviewed the Court of Appeals opinion. Today, in Part II, I want to drill down further and examine the test developed by the Court...more
There have been major developments in the trade, solar cells, US/Chinese antitrust, and securities areas.
REASON FOR THIS NEWSLETTER -
Some readers have commented that this newsletter is...more
Recent news highlights what can happen when companies are not compliant vis-à-vis their trade compliance programs, leading to potential civil and criminal actions. Such actions can cost millions of dollars in penalties,...more
On April 4, 2014, the Department of Justice’s Antitrust Division announced its first successful extradition of a foreign national to the United States on antitrust charges. Romano Pisciotti, a citizen of Italy, has been under...more
Romano Pisciotti, an Italian national, was extradited from Germany in April 2014 to personally face criminal charges in the US for participating in a worldwide cartel. This is the first time an individual has been extradited...more
The news is filled with stories about government investigations into possible violations of antitrust laws: alleged anticompetitive conduct by Google, price fixing by Apple and bid rigging by large financial institutions....more
On April 4, 2014, the U.S. Department of Justice, Antitrust Division announced a milestone victory, having successfully litigated its first extradition for an alleged antitrust violation. Romano Pisciotti, an Italian national...more
With Friday’s announcement of the first-ever extradition of a foreign executive on criminal antitrust charges to the United States, the US Department of Justice has won a major victory in its effort to prosecute and deter...more
For the first time, the U.S. Department of Justice (DOJ) has successfully litigated an extradition of a foreign national on an antitrust charge. This extradition shows that the DOJ is still pursuing individuals it charged...more
New competition provisions may make it easier to prosecute cartel offences, but add additional exclusions and defences.
On 1 April, the competition provisions of the UK’s Enterprise and Regulatory Reform Act (ERRA) came...more
In a groundbreaking decision, the Central District of California became the first court to hold that antitrust violators who received amnesty from criminal prosecution were not entitled to the damages-limiting benefits of the...more
In 2013, the U.S. Department of Justice, Antitrust Division obtained even more record-breaking fines in its ongoing antitrust investigation of the automobile parts industry. The investigation, which began in 2011, has...more
Last week, the Justice Department’s Antitrust Division (the “Division”) filed a motion for rehearing after significant criminal convictions were overturned on statute of limitations grounds. A conspiracy is deemed to continue...more
1 The Legislative Framework of the Cartel Prohibition -
1.1 What is the legal basis and general nature of the cartel prohibition, e.g. is it civil and/or criminal?
The Dutch Competition Act (‘DCA’) is based on...more
Court’s application of statute of limitations will likely guide future conspiracy prosecutions.
On December 9, 2013, the Second Circuit Court of Appeals issued a 2-1 opinion reversing the conviction of three...more
On December 6, 2013, Frank Peake, former president of Sea Star Line LLC, was sentenced to five years in prison and ordered to pay a $25,000 fine for his role in fixing prices for rates and surcharges for freight...more
As global enforcement becomes a reality, companies face a unique set of risks which can be mind-numbing in complications. With the long-arm reach of the FCPA, UK Bribery Act and other anti-corruption laws, more enforcement...more
In This Issue:
- The true cost of fines: Bills would address tax break for corporate fines
- Senate approves new protection for criminal antitrust whistleblowers
- Justice Department sinks ex-Navy...more
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