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New Landmark Foreign Extortion Prevention Act Targets the Demand Side of Foreign Bribery Schemes

On December 22, 2023, President Biden signed into law the landmark, bipartisan Foreign Extortion Prevention Act (the FEPA), as part of the National Defense Authorization Act. Closing a gap in U.S. anti-corruption laws, the...more

U.S. Treasury Department Takes Action Against Russian Darkmarket Entity as Latest Government Move Against Cybercrime

On April 5, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) in the U.S. Department of the Treasury named Genesis Market to OFAC’s Specially Designated Nationals List (“SDN List”). Genesis Market is...more

Biden Describes Combating Corruption as National Security Priority, Orders Interagency Review to Bolster Anti-Corruption Tools...

On June 3, 2021, President Biden issued his first National Security Study Memorandum, announcing that “countering corruption [is] a core United States national security interest.” It describes corruption as a threat to our...more

The Convergence: Feds Level First Hybrid Healthcare- and Securities-fraud Charges Arising from COVID-19 Marketing and Sales

In what may be the beginning of a wave of enforcement actions, the Justice Department charged an organization and its leadership with dual healthcare and securities fraud charges. The prosecution underscores the risks facing...more

Landmark Coronavirus Aid, Relief and Economic Security Act: A Practical Guide

On March 25, 2020, the U.S. Senate passed a $2 trillion federal stimulus package (the largest in U.S. history) by an historic 96-0 vote. The Bill now goes to the U.S. House of Representatives (vote expected Friday, March 27)...more

UPDATE: Trial Court Overturns Former Alstom Executive’s Foreign Corrupt Practices Act Convictions

Former Alstom SA executive Lawrence Hoskins’s jury convictions under the Foreign Corrupt Practices Act (“FCPA”) were set aside on February 26, 2020, by Judge Janet Bond Arterton of the United States District Court for the...more

Former Alstom Executive Convicted of Foreign Corrupt Practices Act Charges on Agency Theory

Lawrence Hoskins, a British citizen and former employee of French conglomerate Alstom SA, has been found guilty by a federal jury in Connecticut of 11 of 12 criminal charges, including six counts of violating the United...more

Organizations Facing Criminal Fines May Be Able To Reduce Them Upon A Proper Showing Of Inability To Pay

So, your organization is about to resolve a criminal matter with the U.S. Department of Justice (DOJ), including agreement as to the appropriate monetary penalty, but it cannot pay that fine or penalty without shutting its...more

Best Practices in the Era of Outside Investigations: Is Your Organization Ready?

Institutions and organizations are increasingly expected to conduct a thorough, neutral investigation of allegations of impropriety, misuse of authority, and sexual harassment, among many other issues. No organization, public...more

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

DOJ Announces One-Year FCPA Enforcement Pilot Program

The U.S. Department of Justice (“DOJ”) Criminal Division yesterday announced that its Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit is conducting a one-year FCPA enforcement pilot program (“Program”). A company...more

DOJ, SEC Change “Cooperation Credit” Process, Add Resources to Fight Corruption

During recent speeches Deputy Attorney General Sally Yates and SEC Enforcement Division head Andrew Ceresney announced changes to the processes the DOJ and the SEC will use to decide if a company will receive “cooperation...more

Dorsey Anti-Corruption Digest - October 2015

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Seventh Circuit Rejects Implied Certification Theory of FCA Liability

Deepening a circuit split, the Seventh Circuit has joined the Fifth Circuit in rejecting the implied false certification theory of liability under the FCA. United States v. Sanford-Brown, Ltd., No. 14-2506 (7th Cir., June 8,...more

SEC Fines KBR $130,000 for Using Employee Confidentiality Agreement that Violates Dodd-Frank Whistleblower Protections

The Securities and Exchange Commission (“SEC”) has brought its first-ever enforcement action against a company for using language in confidentiality agreements that prohibits employees from speaking with the SEC without prior...more

D.C. Circuit grants petition for mandamus and strongly reaffirms attorney-client privilege for internal investigations

The attorney-client privilege has long protected attorney-client communications made during the course of an internal investigation. Upjohn Co. v. United States, 449 U.S. 383 (1983). Of course, the privilege encourages “full...more

Anti-Corruption Digest - April 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

Anti-Corruption Digest - March 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

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