FCPA practitioners tend to repeat themselves. Some of the points we make need to be repeated, and some do not. Businesses are not able to react as quickly as they should in response to potential risks and possible...more
In 2008, Siemens AG paid $800 million to settle charges that it had violated the Foreign Corrupt Practices Act, which generally prohibits bribery of foreign officials for the purpose of obtaining or retaining business. That...more
The healthcare industry has been under increased SEC and DOJ scrutiny lately for potential FCPA violations. What has been described as an “industry sweep,” has focused primarily on medical device and pharmaceutical companies....more
While the FCPA world – and this blog – has been abuzz thanks to the new FCPA Guide, on a relatively mundane note, the U.S. Department of Justice (DOJ) also recently issued two Opinion Procedure Releases (OPRs) with respect to...more
Perhaps I was being overly optimistic. I thought the Justice Department and the SEC could bring a little clarity to the term “instrumentality” in the definition of a “foreign official” under the FCPA. It was wishful...more
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