Legal updates for: FCPA

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The End of the Wild West

by Thomas Fox on

... say the Wild West ended on this day in 1895 when John Wesley Hardin was gunned down in El Paso by the town’s sheriff. Hardin was a legendary gun slinger who is purported to have gunned down over 40 men in his career. He was so mean that he allegedly shot and killed a man for snoring too loudly for his liking. What is clear is that Hardin was... more

Compliance is a Business

by Thomas Fox on

...iance program in their respective areas of influence. Then in April 2016 with the initiation of the DOJ Pilot Program around FCPA enforcement, under the remediation prong, the DOJ once again emphasized the operationalization of a company’s comp... more

Key Energy FCPA Resolution – Part III

by Thomas Fox on

...This week I have been exploring the Key Energy, Inc. (Key Energy) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to consider the actions taken by Key Energy to obtain the very good resolution the compan... more