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DOJ Issues Expedited FCPA Opinion Procedure

In late January 2022, the Department of Justice (“DOJ”) issued Opinion Procedure Release 22-01, its first Foreign Corrupt Practices Act (“FCPA”) Opinion since 2020. The opinion states that based on the specific facts...more

Credit Suisse Settlement Carries Broader Lessons about Reputational Risk

On October 19, 2021, the U.S. Securities and Exchange Commission (“SEC”) announced that Credit Suisse Group AG (Credit Suisse) agreed to pay $100 million to the SEC (among other penalties to other agencies) for violations of...more

World’s Largest Advertising Group Settles with SEC for $19.2 Million After Ignoring Red Flags

On September 24, 2021, the Securities and Exchange Commission (“SEC”) announced a settlement with WPP plc, the world’s largest advertising group with dual headquarters in New York City and London. According to the SEC’s...more

New Action By The CFTC Means Higher Stakes For Commodity Market Participants

The Commodity Futures Trading Commission (“CFTC”) recently announced the settlement of its first enforcement action involving foreign corruption. In December 2020, the CFTC issued a Consent Order, finding that Houston-based...more

Transparency International’s 2020 Corruption Perceptions Index Indicates Corruption Is Affecting COVID-19 Response

On January 28, 2021, Transparency International released its 2020 Corruption Perceptions Index (“CPI”). Transparency International is an organization focused on stopping global corruption and promoting transparency,...more

FCPA: 2020 Year-In-Review

As we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020: •The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies...more

Alert: "Integrity Compliance For Small And Medium Sized Companies" [Part 1]

Never has the need for anti-corruption compliance programs for American companies been greater than it is today. This is not only for large multi-national companies, but for small to medium-sized businesses, particularly...more

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