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Eli Lilly Foreign Corrupt Practices Act (FCPA) Internal Investigations

Dorsey & Whitney LLP

Cooperation, the SEC and FOIA

Dorsey & Whitney LLP on

A critical part of cooperating with an SEC or DOJ investigation for FCPA or other possible violations is the production of documents. In order for the company to assess what happened it must conduct an internal investigation...more

Thomas Fox - Compliance Evangelist

Internal Audit Review of Charitable Donations Under the FCPA

When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and it violates the Foreign Corrupt Practices Act (FCPA). I thought about that concept when reviewing the Eli Lilly and Company...more

Thomas Fox - Compliance Evangelist

Top Ten Enforcement Actions for 2012

As we welcome in 2013, it is appropriate to reflect back on some of the things which have occurred over 2012 and in the Foreign Corrupt Practices Act (FCPA) enforcement world, it was quite a significant year. The Department...more

Thomas Fox - Compliance Evangelist

The Lilly FCPA Enforcement Action (Part III) Lessons Learned from Russia

This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more

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