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Second Circuit Reinforces FCPA’s Jurisdictional Limits

Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties. Key Points: ..Non-resident foreign nationals who are not otherwise subject to direct...more

DOJ Expands and Codifies Policy Incentivizing Corporations to Voluntarily Self-Disclose FCPA Violations

The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties. ...more

DOJ Announces Continuation and Ongoing Review of FCPA Pilot Program

The extension of the program — which emphasizes voluntary self-disclosure of FCPA violations, raises considerations for corporate entities and individual executives. The Department of Justice (DOJ) recently announced...more

US Department of Justice Guidance Seeks to Encourage Voluntary Self-Disclosure of Export Controls and Sanctions Violations

The Guidance parallels the DOJ approach under the FCPA, but does not specify the value of mitigation and may create contradictory incentives. The National Security Division (NSD) of the US Department of Justice (DOJ)...more

DOJ Guidance Underscores Importance of Anti-corruption Due Diligence in International M&A Transactions

FCPA Opinion Release provides insight into the jurisdictional reach of the FCPA and the level of due diligence the DOJ expects. On November 7, 2014, the US Department of Justice (DOJ) issued its second and final...more

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