Latin America has been especially hard hit in recent months by the ongoing COVID-19 pandemic. The resulting travel restrictions, physical safety precautions and public health concerns have created uncertainty for many...more
On July 3, 2020, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) released the second edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (2020 Guide), the first update to...more
Although the response to the COVID-19 pandemic has significantly disrupted the courts and US prosecutors and regulators, that disruption will not last indefinitely. As government prosecutors and regulators adjust to these new...more
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
12/31/2019
/ Accounting Controls ,
Bribery ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Counsel ,
Corporate Culture ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Ericsson ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Jurisdiction ,
Meals-Gifts-and Entertainment Rules ,
Popular ,
Remediation ,
Securities and Exchange Commission (SEC)
On May 2, 2019, a court in the Southern District of New York ruled in United States v. Connolly (16-CR-370) that statements made by an employee to outside counsel during an internal investigation were subject to certain...more
Despite generally favorable macroeconomic conditions, high levels of cash among strategic acquirers and low interest rates, the number of reported M&A transactions and deal value worldwide both declined for the second...more
I. Introduction: Enforcement Trends and Priorities -
Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more
2/3/2016
/ Bank of New York (BNY) Mellon ,
BHP Billiton ,
Blocking Statutes ,
Bristol-Myers Squibb ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Statistics ,
FLIR System ,
Foreign Corrupt Practices Act (FCPA) ,
Hitachi ,
Olympics ,
Strict Liability ,
Yates Memorandum
The Department of Justice has released a new policy intended to further the Department’s effort to hold individuals accountable for corporate wrongdoing. The policy was laid out in a September 9, 2015 memorandum authored by...more
For the second time in just over a year, the DC Circuit granted the extraordinary remedy of a writ of mandamus to protect a company’s assertion of privilege over materials relating to an internal investigation. In a...more
9/3/2015
/ Appeals ,
Attorney-Client Privilege ,
Defense Sector ,
Document Productions ,
False Claims Act (FCA) ,
Federal Contractors ,
Federal Rules of Evidence ,
Internal Investigations ,
KBR (formerly Kellogg Brown & Root) ,
Waivers ,
Work-Product Doctrine ,
Writ of Mandamus