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Revised DOJ Corporate Cooperation Policy Paints a Target on Individuals

Last week, at the American Conference Institute’s 35th International Conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod Rosenstein introduced revisions to the Department of Justice’s (DOJ)...more

Second Circuit Rejects DOJ's Expansive Theory of Conspiracy and Accomplice Liability Under the FCPA for Foreign Nationals

On August 24, 2018, nearly 18 months after hearing oral argument, the U.S. Court of Appeals for the Second Circuit issued a decision in United States v. Hoskins, that significantly limits the Department of Justice’s (“DOJ”)...more

Foreign Corrupt Practices Act 2017 Year-End Update

2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more

Foreign Corrupt Practices Act 2017 Mid-Year Update

The first half of 2017 has been eagerly anticipated following the record-setting year in 2016 for Foreign Corrupt Practices Act (“FCPA”) enforcement by both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and...more

Justice Department Sets Standards for Evaluation of Corporate Compliance Programs

Since the Department of Justice’s (“DOJ”) announcement of its new compliance counsel expert in November 2015, many have been waiting patiently for additional insight into the DOJ’s emphasis on corporate compliance programs....more

New AG Sessions Promises to Enforce FCPA and Hold Individuals Accountable

Following a record year for Foreign Corrupt Practices Act (“FCPA”) enforcement and policy declarations affecting corporate actors, recent statements by U.S. Attorney General Jeff Sessions confirms that the new administration...more

Foreign Corrupt Practices Act 2016 Year-End Update

2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more

FCPA and Jail - Are Corporate Officers Really at Risk?

On Oct. 31, James McClung, a former Louis Berger International Inc. executive, self-surrendered to the Bureau of Prisons to begin his year-and-a-day sentence for violations of the Foreign Corrupt Practices Act (FCPA)....more

Foreign Corrupt Practices Act 2015 Year-End Update

Both the United States Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) have continued their focus on anticorruption enforcement in 2015. Although there was a decline in enforcement...more

DOJ Attempts to Encourage Corporate Self-Disclosures With the Announcement of a One-Year FCPA Pilot Program

Pursuing a classic “carrot and stick” approach to incentivizing corporate self-disclosure of FCPA violations and individual wrongdoing connected to FCPA violations, the Department of Justice (DOJ) Fraud Section announced a...more

Global Tax Enforcement in 2016: What You Need to Know

The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more

Pointing the Finger The New Price of Corporate Cooperation

On September 9, 2015, Sally Quillian Yates, the Deputy Attorney General, issued a memorandum announcing the Department of Justice’s (DOJ) new guidelines regarding its intensifying focus on individual wrongdoers in the context...more

Pulling Back the Curtain: DOJ to Take Action Against Window Dressing Corporate Compliance Programs

On July 30, 2015, Andrew Weissman, the chief of the Fraud Section of the U.S. Department of Justice (DOJ) Criminal Division, announced that the DOJ is in the process of hiring a former prosecutor to serve as a full-time...more

Justice to Target Corporations and C-Suite Executives in the Healthcare Industry

On Thursday, May 14, 2015, at a meeting of the American Bar Association’s Healthcare Fraud Section, Leslie Caldwell, the Assistant Attorney General for the Department of Justice (DOJ) Criminal Division, declared stamping out...more

No Room for Companies to Gamble as the Feds Double Down on FCPA Enforcement

In 2014, a record-setting year for Foreign Corrupt Practices Act (FCPA) enforcement, the Department of Justice (DOJ) announced the largest-ever DOJ FCPA resolution—an over $772 million criminal fine for French power company...more

Foreign Corrupt Practices Act 2014 Year End Update

Over the course of 2014, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) have continued their aggressive enforcement of the Foreign Corrupt Practices Act (“FCPA”). This has led to critical...more

Foreign Corrupt Practices Act - 2014 Mid-Year Update

The first half of 2014 has seen several important developments in the enforcement of the Foreign Corrupt Practices Act (“FCPA”) as well as other anti-corruption laws worldwide. The FCPA has been in existence for more than 35...more

Corruption Enforcement Goes Global

As BakerHostetler recently reported in its FCPA Mid-Year Update, the phenomenon of parallel prosecutions is gaining popularity as more countries enact and enforce anti-corruption legislation....more

The Floodgates are Open: Second Whistleblower Award Sparks Speculation Over What's Next

Last week, the Securities and Exchange Commission (SEC) issued an order awarding three whistleblower awards to tipsters who helped the SEC with its enforcement action against Locust Offshore Management, LLC and its CEO Andrey...more

Total S.A. to Pay $398.2M to Settle Alleged FCPA Violations

On May 29, 2013, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced agreements with Total S.A. (Total) to settle alleged Foreign Corrupt Practices Act (FCPA or the Act) violations for a...more

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