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Revisions To FCPA Enforcement Policies Still Pose Tough Questions For Honest Companies

In recent remarks, Deputy Attorney General Rod Rosenstein announced significant revisions to the Department of Justice’s (DOJ) policies for enforcing the Foreign Corrupt Practices Act. The policy revisions make permanent...more

Second Circuit Limits FCPA Enforcement Tools

In its recent decision in United States v. Allen, 16-cr-898, the Second Circuit Court of Appeals held that testimony which is compelled pursuant to laws of foreign jurisdictions violates the Fifth Amendment right against...more

Complex FCPA Plea Agreement Gives Federal Court Pause

On June 16, 2016, Teva Pharmaceutical’s Russian subsidiary (Teva LLC) pled guilty to one count of conspiring to violate the Foreign Corrupt Practices Act (FCPA). Judge Kathleen M. Williams of the United States District Court...more

Are Siemens’ FCPA Compliance Efforts Public Information?

In 2008, global technology giant Siemens Aktiengesellschaft (“Siemens”) pleaded guilty to violations of the books and records provision of the Foreign Corrupt Practices Act (“FCPA”). Siemens paid approximately $450 million...more

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