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Lessons Learned from the BizJet Executives FCPA Enforcement Actions [Video]

BizJet self-disclosed to the DOJ, engaged in what the DOJ termed “extraordinary cooperation” and remediated the people and conduct in question. Further, DuBois and Uhl not only offered themselves up but actively worked with...more

California Bill Would Expand Liability For Securities Fraud, Impose New Fees, Expand Commissioner’s Powers

In late February, Senator Jerry Hill introduced a bill, SB 538, to substantially amend the Franchise Investment Law. A few days later, the bill was read for the first time and set for hearing by the Senate Banking and...more

Using History to Create or Rebuild a Compliance Culture

I have worked for and with a number of companies that may seem to have lost their compliance path and have become embroiled in a lengthy Foreign Corrupt Practices Act (FCPA) or UK Bribery Act investigation. They may need to...more

Will the UK Let the Light of Day Shine Into Its Regulatory Process

Should the regulators process be shrouded in mystery or should there be disclosure into the light of day? That is a question currently before authorities in London. As reported in the Financial Times (FT) column Inside...more

Pfizer DPA Part II – Enhanced Compliance Obligations and Corporate Compliance Obligations

Last week I began an exploration of the Pfizer Deferred Prosecution Agreement (DPA) which was announced last week by the Department of Justice (DOJ) in connection with its settlement of Foreign Corrupt Practices Act (FCPA)...more

Barclay’s Speeding Defense and GlaxoSmithKline’s Claw backs – Implications for FCPA Compliance

I once heard James Baker say that the only way to know how a person will perform as President of the United States is by being President. In other words, there is no way to test how a person will respond to the stresses and...more

Franchsing and the FCPA

The Foreign Corrupt Practices Act (FCPA) applies to all US companies and individuals which conduct business overseas. FPCA practitioners recognize there are two components: (1) the anti-bribery component, handled by the...more

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