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Foreign Corrupt Practices Act (FCPA) Internal Investigations Investigations

Troutman Pepper

Lessons Learned from the FCPA Pilot Program's First Six Months

Troutman Pepper on

The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

Thomas Fox - Compliance Evangelist

A Surprise in Progressive Rock – FCPA Internal Investigations

The case has a long involved Foreign Corrupt Practices Act (FCPA) history. It involves Panalpina and its customer Shell. David Smyth, in his great blog Cady Bar the Door, reported, in a post entitled “Texas Court of Appeals...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 64-Managing the Third Party Relationship Under the FCPA, Part II

In this episode I continue my review of the five steps of managing third parties under the FCPA. In this part II, I discuss steps 3-5....more

Latham & Watkins LLP

Three Practical Steps to Managing FCPA & Anti-Corruption Risks

Latham & Watkins LLP on

Foreign Corrupt Practices Act (FCPA) enforcement continues to be a priority for the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC). In recent years, U.S. authorities have aggressively...more

Thomas Fox - Compliance Evangelist

On The Oregon Trail And Expectations In An Investigation Protocol

On this day in 1843, a massive wagon train, made up of 1,000 settlers and 1,000 head of cattle, set off down the Oregon Trail from Independence, Missouri. Known as the “Great Emigration,” the expedition came two years after...more

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