Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more
As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division, in July, released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations...more
The department laid out a bold new policy providing “presumption” of non-prosecution for companies that self-report FCPA violations and meet other conditions....more
The world of science fiction can be exhilarating. If you ever read The Foundation Trilogy or Martian Chronicles, you know what I mean. The concept of parallel universes has always been an intriguing idea where believers can...more
The United States Department of Justice (DOJ) Antitrust Division offers immunity from prosecution to applicants who are the first to self-report antitrust violations. That immunity carries with it limited protection from...more
The Department of Justice (DOJ or Department) released updated guidance on the Antitrust Division’s Leniency Program, on January 17, 2017. The Leniency Program allows corporations and individuals who self-report their cartel...more