On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (AAG Polite) announced changes to the Department of Justice’s (DOJ) FCPA Corporate Enforcement Policy (CEP). The CEP, which applies to all Criminal...more
1/25/2023
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Priorities ,
Forfeiture ,
Restitution ,
Voluntary Disclosure ,
White Collar Crimes
On February 26, 2020, the US District Court for the District of Connecticut reinforced the Second Circuit’s recent decision to limit prosecutors’ ability to pursue Foreign Corrupt Practices Act (FCPA) charges against foreign...more
3/4/2020
/ Acquittals ,
Agency Relationship ,
Alstom ,
Bribery ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Indictments ,
Jurisdiction ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
On December 2, 2019, a jury in the Eastern District of New York acquitted Jean Boustani, a Lebanese citizen who is alleged to have been a key player in coordinating more than $200 million in bribe and kickback payments to...more
12/13/2019
/ Acquittals ,
Bribery ,
Credit Suisse ,
Criminal Prosecution ,
Extraterritoriality Rules ,
Foreign Nationals ,
Fraud ,
Indictments ,
Kickbacks ,
Misrepresentation ,
Mozambique ,
Nexus ,
Securities Fraud ,
Venue
The extraterritorial reach of statutes seeking to prohibit unscrupulous financial practices has been debated and watched as both entities and individuals seek to determine the scope of the United States’ government’s ability...more
On August 9, 2019, the US Court of Appeals for the Second Circuit upheld a Chinese real estate developer’s conviction in United States v. Ng Lap Seng. The Court rejected defendant’s attempt to read an “official act”...more
On March 6, 2019, Mobile TeleSystems PJSC (MTS) consented to pay an $850 million sanction—the largest Foreign Corrupt Practices Act (FCPA) criminal penalty ever paid to the United States—and to a three-year monitorship to...more
On November 29, 2018, the US Department of Justice (DOJ) modified prior guidance on individual liability for corporate misconduct by affording federal prosecutors discretion to focus on “individuals who play significant roles...more
A former banker has agreed to forfeit $43.7 million and has pled guilty to Foreign Corrupt Practices Act (FCPA) violations and money laundering in one of the largest individual FCPA enforcement cases to date. The two-count...more
On August 24, 2018, the US Court of Appeals for the Second Circuit in United States v. Hoskins rejected the government’s broad reading of the Foreign Corrupt Practices Act (FCPA) and ruled that a foreign national without ties...more
On June 4, 2018, Société Générale S.A., together with a subsidiary of the Paris-based global financial services institution, announced an agreement with both French and American authorities to resolve charges relating to...more
6/13/2018
/ Bribery ,
Criminal Investigations ,
Criminal Prosecution ,
Cross-Border ,
Department of Justice (DOJ) ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Governments ,
France ,
Libor ,
Multinationals ,
Popular ,
Price Manipulation