FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue
FCPA Compliance and Ethics Report-Episode 119-FCPA Year in Review, Part I
Following a nine month trial in 2019, Mr. Justice Hildyard released a summary of his conclusions at the end of January 2021 regarding the proceedings brought by Hewlett-Packard (“HP”) (as well as a number of related entities)...more
When DOJ acts, they like to make a splash. While the FCPA Paparazzi have been lamenting the “slow down” in FCPA enforcement actions and the increase in case closings, DOJ still makes its mark when it acts, and I expect more...more
One of the critical areas in due diligence for foreign business partners is determining who are the true owners of an entity....more
Doing something ‘by the book’ means more than following a process. It means following that process during high stress times. One of the things that I think gets missed when discussing compliance programs is the need for rigor...more