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Integrating and Training Your Agents and Distributors (Part II of IV)

The Department of Justice and the SEC know they can push companies to expand and improve their anti-corruption compliance programs. They are well aware that the requirements set forth in their settlement documents, as well as...more

Distributors under the FCPA

If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made it emphatically clear that...more

From China to Poland and Brazi l- The Lilly FCPA Enforcement Action- Part II

In Parts II and III of my review of the Eli Lilly and Company (Lilly) Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC), I will discuss some the processes and...more

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