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New Guidance from the DOJ on Your Compliance Program

The U.S. Department of Justice (DOJ), Criminal Division, Fraud Section, recently released new guidance associated with its Guide to the U.S. Foreign Corrupt Practices Act. The guidance, entitled Evaluation of Corporate...more

DOJ Fraud Section Unveils Blueprint for Assessing Corporate Compliance Programs

In the year and a half that has transpired since the DOJ's Fraud Section retained a compliance consultant to assist prosecutors' evaluation of compliance programs, compliance officers, general counsels and white-collar...more

Individual Defense in the Shadow of Corporate Guilty Pleas

Recent corporate guilty pleas can be expected to have serious implications for the individual executives and employees alleged to have been involved in the conduct under scrutiny. But there are other factors at play in such...more

Red Notice Newsletters - Chinese

ANTICORRUPTION DEVELOPMENTS - Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action – On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more

Top Ten International Anti-Corruption Developments for December 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

"DOJ Updates Leniency Program FAQs"

The Department of Justice (DOJ or Department) released updated guidance on the Antitrust Division’s Leniency Program, on January 17, 2017. The Leniency Program allows corporations and individuals who self-report their cartel...more

SFO and Rolls-Royce agree to half billion pound DPA

Just over a year after the approval of the first ever Deferred Prosecution Agreement (DPA), Southwark Crown Court on 17 January 2017 approved a DPA proposed by the Serious Fraud Office (SFO) with UK leading engineering group,...more

Frequently Asked Questions About the Amnesty Program—Major Changes in the Antitrust Division’s January 2017 Update

In the past, the Antitrust Division has used its “Frequently Asked Questions” piece to announce significant changes in the Amnesty Program. In November 2008, for example, they made mandatory an explicit admission of criminal...more

Judged by the Company You Keep

Earlier this month news broke that the venerable British automaker Rolls-Royce had settled an international prosecution alleging that the company’s third-party intermediaries bribed local officials in Asia. The company agreed...more

Avoiding Bribery Violations During This Year’s Gift-Giving Season in Korea

Happy New Year of the rooster! This week marks the beginning of Seollal, or the Lunar New Year, which is one of the most significant holidays in Korea and the greater Asia region. During this celebratory season, multinational...more

Foreign Corrupt Practices Act 2016 Year-End Update

2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more

Company Directors Beware – the CMA’s Disqualification Order

Today, the UK Competition and Markets Authority (CMA) published a 60-second summary for company directors to avoid disqualification for breaches of competition law. Please see the full text of the guidance here. This is part...more

VW Fallout Continues: Mobile Source Emissions Enforcement Likely to Continue Full Speed Ahead under Trump Administration

The headlines generated by the Volkswagen emissions scandal continue to amaze the environmental community and the general public, both here and abroad. The events are shocking in part because they involve a household name in...more

2016 Global Cartel Enforcement Report

Authorities launched new criminal probes, obtained guilty pleas from companies and executives and imposed hefty fines as aggressive enforcement continued. Several significant developments occurred in cartel enforcement...more

Defence & Indemnity - December 2016: I. INSURANCE ISSUES A.

A. An insured killed by a thief driving the insured’s vehicle is entitled to coverage under his S.P.F. 44 Endorsement, notwithstanding that one part of the definition of “inadequately insured motorist” purports to exclude...more

The Implications of Insureds’ Illegal Conduct

Allegations of corporate bribery and corruption are increasingly frequent. According to a recent report by PwC, the World Bank estimates that more than $1 trillion is paid in bribes each year and 55 percent of global CEOs...more

Blog: Government Considering Reform To Hold Companies More Accountable For Economic Crime

The Ministry of Justice has announced that it has commenced a consultation with businesses on the introduction of legislation aimed at tackling corporate economic crime and is seeking views on the extent to which reform is...more

Reform of corporate criminal liability for economic crime

On 13 January, the UK Ministry of Justice issued a Call for Evidence on the reform of corporate criminal liability for economic crime. This follows statements by the UK government in 2016 about extending corporate criminal...more

OFSI’s New Power to Issue Monetary Fines for Sanctions Breaches: Consultation

The consequences of breaching sanctions in the UK are due to increase in April. Prominent among the new measures is the power for the Office of Financial Sanctions Implementation (OFSI) to impose a monetary penalty and to do...more

Update on Sapin II law

On 8 November 2016, the French Parliament passed a law targeting transparency, anti-corruption and the modernisation of the economy, known as the Sapin II Law. This law entered into force on 11 December 2016. Consequently,...more

Enforcement Of Arbitral Award Refused: A Tale Of Dirty Deals, Demurrage And Discontent

Pursuant to article V of the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, a national authority may refuse to enforce or recognise a foreign award on certain limited grounds,...more

Actualite Juridique - Decembre 2016

Assurance - Résiliation d'un contrat d'assurance emprunteur pour cause d'aggravation du risque - Le Décret n°2016-1559 du 18 novembre 2016 relatif aux conditions de résiliation d'un contrat d'assurance emprunteur...more

Insider Trading Law After Salman v. United States

In Salman v. United States, decided on December 6, 2016, the Supreme Court upheld a conviction for criminal violations of insider trading laws. The Court, however, declined to adopt the expansive theories of insider trading...more

2016 – A Bad Year For Bad Guys in Energy

Let’s look back at a cavalcade of crooks, criminals and miscreants who met up with justice in 2016. We do it to be reminded of the others who will be lurking in the 2017 shadows....more

[Webinar] Business E-mail Compromise Scams - Practical Perspectives - January 12th, 10:30am EST

An increasing number of businesses are targeted by very sophisticated email scams designed to convince company employees responsible for executing financial transactions to wire funds to overseas accounts controlled by...more

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