This Week in FCPA-Episode 80, The Last Jedi Edition
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
Earlier this year, the Department of Justice’s (DOJ) Foreign Agents Registration Act (FARA) Unit entered into what appeared to be the first publicly announced deferred prosecution agreements (DPAs) to resolve alleged FARA...more
Since his election, President Joe Biden has loudly reaffirmed U.S. ambitions in the fight against global corruption, domestically and abroad. Thus, in June 2021 the “Biden memorandum” declared the fight against...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption developments from the past month, with links to...more
In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
Despite the ongoing coronavirus (COVID-19) pandemic, the work of antitrust enforcers has continued largely uninterrupted in the second half of 2020. The Department of Justice Antitrust Division (the “Division”) has announced...more
On September 29, 2020, US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving...more
On June 25, 2020, Novartis AG, a Swiss multinational pharmaceutical company, and two subsidiaries reached a combined $345 million resolution with the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange...more
Throughout the first half of 2020, much of the world has grappled with the reality of the coronavirus (COVID-19) pandemic, as the outbreak spread rapidly across entire countries and shut down large segments of the global...more
On April 14, 2020, for the first time, the Department of Justice (“DOJ”) published a list identifying all corporate monitors actively engaged by companies as a part of criminal resolutions with the Criminal Division’s Fraud...more
On April 23, 2019, the US Department of Justice (DOJ) announced it has entered into a deferred prosecution agreement with Rochester Drug Co-Operative, Inc. (RDC), one of the 10 largest wholesale distributors of pharmaceutical...more
Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more
Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more
Things are seriously bad when one of the world’s most respected business focused publications, the Financial Times (FT), asks if the auto “industry faces ‘Libor moment’”? Yet that was a headline yesterday in the lead article...more
The DOJ’s Yates Memo makes individual prosecutions a higher priority and makes a company’s own identification of potentially culpable individuals an explicit factor in assessing cooperation credit....more
The Justice Department can surprise you – the release of the Yates Memo, as it is commonly referred to since it takes on the name of the Deputy Attorney General (e.g. McNulty Memo), is another strange example of DOJ...more
On September 9, 2015, the U.S. Department of Justice announced a new policy regarding individual accountability for corporate misconduct. The policy, described in a memo authored by Deputy Attorney General Sally Yates,...more
A federal judge exceeded his authority when he rejected a deferred prosecution agreement (DPA) entered into earlier this year by the U.S. Department of Justice (DOJ) and a Dutch aerospace company, the DOJ and company will...more