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DOJ Clarifies Successor Liability for Foreign Acquisitions in Latest Opinion Release

Earlier this week, the U.S. Department of Justice (DOJ) issued its second public opinion release of the year in response to a question posed regarding the applicability of the U.S. Foreign Corrupt Practices Act (FCPA) to a...more

Gifts of Travel and Luxury Watches to Saudi Officials Not Mere 'Icing on the Cake' for FCPA Charges

Improper Gifts Alone, Without Cash Bribes, Serve as Basis for SEC’s Latest FCPA Enforcement Action - Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating...more

Michael Garcia Now Just Taunting FIFA

And I say that in the most complimentary way. If you haven’t been following this story, here’s a quick recap: FIFA awarded the 2018 and 2022 World Cups to Russia and Qatar, respectively. This raised eyebrows, as they say. ...more

“Is the Current Compliance Model Working?”

An interview with Richard Bistrong. You must read it. Find out about bribery from the front line from someone who has been there, seen it, done it and got the jumpsuit. Originally published on...more

Clear Expectations: DOJ Outlines Tenets of an Effective Antitrust Compliance Program

There has never been a greater emphasis on policing anticompetitive behavior worldwide. Dozens of countries have instituted effective and aggressive cartel enforcement programs following a trend of increased global...more

Cartel Prosecutions – The Next Wave and the New Message from the U.S. Antitrust Division

It is widely rumored that the U.S. Antitrust Division of the Department of Justice (“Antitrust Division”) is already working toward its next wave of international cartel investigations. The blockbuster auto parts...more

Recent FCPA Enforcement Actions: The Layne Christensen Case and SBM Offshore

The Fourth Quarter of 2014 has been a busy one for DOJ and SEC in the FCPA arena. We are all praying that DOJ and SEC resolve the Avon case soon so that we do not have to include the case on our lists for predictions for...more

The Financial Report - Volume 3, No. 21 • November 2014 (Global)

Criminal securities fraud charges filed against Bitcoin operator. US federal prosecutors filed the first criminal securities fraud charges involving a virtual currency. Trendon Shavers, who founded Bitcoin Savings and...more

Why Sanctions Alone Are Not Enough: The Nigerian Model

Q: Hello Sven. I feel like I know you through your three part series in the Journal of Business Compliance, and our soon to be published roundtable. So, could you tell us a little about today’s Q and A?...more

The long arm of the law: exporting US justice

As individual jail terms and corporate fines continue to increase, many companies and executives outside the United States are left wondering: How are US laws able to reach so far outside US borders? The United States has...more

This Week In Securities Litigation

Supreme Court Justices Scalia and Thomas indicated that the High Court may at some point consider a question regarding the application of insider trading law in criminal cases and the deference due, if any, to the...more

Banks Settle with U.K. Regulatory Authority Over Forex Manipulation

Today it was announced that six banks settled with the U.K. Financial Conduct Authority and other regulators for a combined total of approximately $4.3 billion for their roles in the manipulation of the $5.3 trillion-a-day...more

AUSTRALIA: Hitting Corruption for Six

The cricket world is in a fierce battle against the increasing use of technology in illegal bookmaking. In order to protect their interests ahead of the World Cup starting in February 2015, the International Cricket Council...more

Money Laundering in the News: Los Angeles Fashion District Raid Puts Trade-Based Money Laundering and Black Market Peso Exchange...

On September 10, 2014, federal and local law enforcement officials raided the Los Angeles Fashion District in an effort to combat alleged money laundering for Mexican drug cartels which was occurring within the District. The...more

Confession: Good for the Soul, but Bad for Business?

A few days ago, your company filed a voluntary disclosure with the Directorate of Defense Trade Controls stating that you violated the ITAR in an export transaction. Your in-house counsel told you that you had to file quickly...more

Voluntary Disclosure: The Continuing Debate

For years (okay 3 years), I have written about the need for DOJ to address its policies surrounding voluntary disclosure. DOJ and the SEC regularly urge companies and FCPA practitioners to disclose FCPA violations to DOJ in...more

Supreme Court Declines to Review 3rd Circuit Ruling; Crime-Fraud Exception to Attorney-Client Privilege Decision Persists

On November 10, 2014, the Supreme Court (No. 14-389) declined to review the 3rd Circuit decision (No. 13-1237), In Re: Grand Jury Subpoena, leaving intact the 3rd Circuit’s ruling on the proper bounds of the crime-fraud...more

Bribery and the Classroom (not in the Classroom)

“Mr. Bistrong, in the complaint it was alleged that you were a conspirator in bribing foreign officials in multiple countries, such as Nigeria, the UK, and the Netherlands, as well as bribing UN officials. Were there...more

Deferred Prosecution Agreements Authorised & “Whistleblower” Bounties Rejected: Clues to Future Enforcement of U.K. Financial...

In the second of three posts on the future enforcement of U.K. financial crimes, we explore the implications of enforcement actions related to financial crime in the U.K. To see all four clues and a roadmap for implementing...more

Jail Time & Multi-National Cooperation in Investigations: Clues to Future Enforcement of U.K. Financial Crimes

In the first of three posts on the future enforcement of U.K. financial crimes, we explore the implications of enforcement actions in the U.K. To see all four clues and a roadmap for implementing an effective business conduct...more

Top 4 Benefits of Self-Reporting FCPA Violations

Violations of the U.S. Foreign Corrupt Practice Act (FCPA) can lead to significant fines and serious consequences, leaving many to wonder why an organization would opt to voluntarily disclose violations. This is exactly what...more

Exchange – International Newsletter: Issue 24 – October 2014

WELCOME - DLA Piper’s Financial Services International Regulatory team welcomes you to the twenty-fourth edition of ‘Exchange – International’ – an international newsletter designed to keep you informed of regulatory...more

SEC – DOJ Resolve FCPA Charges With Bio-Rad Labs

The SEC and the DOJ resolved FCPA charges with California based life science research and clinical diagnostics company Bio-Rad Laboratories, Inc. The charges stem from bribes paid in Russia, Vietnam and Thailand. The company...more

This Week In Securities Litigation

The Commission brought a series of administrative proceedings this week and one civil injunctive action. The civil injunctive action was an insider trading case. The administrative proceedings centered on FCPA violations, the...more

Knowing When to Fold — Arguing the FCPA’s Definition of “Foreign Official”

With lots of fanfare, Esquenazi and Rodriguez, and the usual suspects filed a cert petition and briefs in support of the appeal from the 11th Circuit Court of Appeals’ decision affirming the lower court’s interpretation of...more

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