The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more
2/8/2017
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Popular ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure
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