Red Notice Newsletter - August 2018

Paul Butler, Chris Chamberlain, Christian Davis, Suzanne Kane, Sina Kimiagar, Sarah Kirwin, Abigail Kay Kohlman, Melissa Whitaker
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ANTICORRUPTION DEVELOPMENTS -

$34 Million SEC Settlement for Legg Mason -

On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an investigation related to the conduct of a subsidiary in Libya. This resolution comes after Legg Mason agreed to pay $64.2 million to settle an investigation by the Department of Justice (DOJ) into the same conduct. The Libya investigations were previously covered in the June 2018 edition of Red Notice.

U.S. Appeals Court Limits Jurisdiction of FCPA -

On August 24, 2018, the U.S. Court of Appeals for the 2nd Circuit affirmed in part a ruling from the U.S. District Court of Connecticut and held that conspiracy liability to violate the Foreign Corrupt Practices Act (FCPA) does not extend to a foreign individual if the foreign individual never entered the United States to commit the alleged misconduct and the foreign individual did not operate as an agent, employee, shareholder, director or officer of a U.S. company or citizen...

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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