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Legal Update: Department of Justice National Security Division Announces First-of-Its-Kind Declination under Its Voluntary...

On May 22, 2024, the Department of Justice (DOJ) announced the first-ever declination under the National Security Division’s recently updated Enforcement Policy for Business Organizations (NSD Policy). The NSD Policy offers...more

DOJ Announces Significant Corporate Compliance Initiatives

The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more

Historic $2.9 Billion Anti-Bribery Settlement Has Important Takeaways for Manufacturers

It would be a mistake to think that the $2.9 billion settlement Goldman Sachs Group Inc. has agreed to pay in order to resolve allegations of widespread bribes to government officials in Malaysia and the United Arab Emirates...more

DOJ’s Latest FCPA Pressure Tactic: Charging Multiple Violations for Single Alleged Payment Scheme

The Foreign Corrupt Practices Act (“FCPA”) prohibits paying or offering bribes to foreign officials to obtain business advantage. In some instances, the paying or offering of bribes prohibited by the FCPA may involve multiple...more

Conviction of Foreign Employee Reinforces Broad Geographic Reach of FCPA

Last week, a jury found a former executive of a French multinational company guilty of violating the Foreign Corrupt Practices Act, money laundering, and conspiracy in connection with alleged bribery in Indonesia....more

Department of Justice Expands Guidance on Evaluating Corporate Compliance Programs

Earlier this year, the United States Department of Justice (DOJ) issued new guidance regarding how it evaluates corporate compliance programs in the context of civil and criminal enforcement matters....more

Second Circuit Decision Rejects Expansion of Geographic Reach of FCPA

A Brief Overview of the FCPA - The Foreign Corrupt Practices Act (FCPA) is a federal statute that prohibits United States companies and individuals from bribing foreign government officials in order to gain or retain...more

Settlement with Swedish Telecom Giant Falls Just Short of First $1 Billion FCPA Resolution

In September, the U.S. government announced a nearly $1 billion FCPA (Foreign Corrupt Practices Act) settlement with the Swedish telecommunications company Telia. The total monetary payment in this global resolution makes it...more

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