This is the third in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed sanctions and export control trends....more
3/19/2021
/ Anti-Corruption ,
Asia ,
Biden Administration ,
CFTC ,
Compliance ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Latin America ,
NDAA ,
Securities and Exchange Commission (SEC) ,
UK ,
White Collar Crimes
On July 3, 2020, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) released the Second Edition of their Resource Guide to the U.S. Foreign Corrupt Practices Act (the “Resource Guide”). As...more
7/7/2020
/ Aiding and Abetting ,
Bribery ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Disgorgement ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Mens Rea ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations
Editors’ Note: This is the third in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed healthcare fraud in 2020. Up next: a look at...more
1/13/2020
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
Internal Controls ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
In December, the Department of Justice (DOJ) announced the release of a new policy for business organizations regarding voluntary self-disclosures of export control and sanctions violations. The new Policy makes explicit that...more
This week the U.S. Department of Justice (DOJ) Criminal Division released revised guidance on the “Evaluation of Corporate Compliance Programs.” This latest guidance is important not only to help benchmark existing...more
Introduction -
In the recent, long-awaited decision in United States v. Hoskins, the U.S. Court of Appeals for the Second Circuit rejected the expansive interpretation of FCPA jurisdiction over foreign individuals put...more
Under the new FCPA Corporate Enforcement Policy recently released by the Department of Justice (“DOJ”), when a company has voluntarily self-disclosed misconduct, fully cooperated in the government’s ensuing investigation, and...more
The U.S. Foreign Corrupt Practices Act turned forty this year. The Department of Justice is marking that anniversary by announcing a new Corporate Enforcement Policy specific to FCPA matters. The new Policy makes explicit...more
A recent federal court decision highlights the increasing risk of prosecution for foreign national executives under the Foreign Corrupt Practices Act ("FCPA”). The decision from the federal district court in New York denied...more