As 2018 came to an end, a voluntary disclosure to the U.S. Department of Justice ("DOJ") and the Securities and Exchange Commission (“SEC”) by U.S.-based agribusiness, CHS, Inc. (“CHS”), of potential violations of the Foreign...more
A high-level U.S. Department of Justice (“DOJ”) official recently stated that a Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy, which incentivizes self-disclosure, also applies to U.S. companies merging...more
Welcome to the spring edition of our White Collar Watch. Hopefully by the time you are reading this, winter’s storms (finally?) are behind us.
2018 has gotten off to a busy start for our practice and attorneys. We look...more
5/1/2018
/ Anti-Corruption ,
Anti-Money Laundering ,
Certiorari ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Environmental Protection Agency (EPA) ,
False Claims Act (FCA) ,
Financial Institutions ,
FinTech ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
Lagos v United States ,
Qui Tam ,
Recordkeeping Requirements ,
SCOTUS ,
Securities and Exchange Commission (SEC)
On February 14, 2018, another major financial institution disclosed that it is under investigation for possible violations of the Foreign Corrupt Practices Act (“FCPA”). This disclosure comes at a time when the Department of...more
The U.S. Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") issued 15 declination letters in 2017 notifying companies of their decision not to pursue charges in connection with alleged violations...more
Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more
7/25/2017
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Compliance ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more
Welcome to the summer 2017 edition of Mainbrace. To say we live in interesting times would be a serious understatement. We read headlines on a daily basis that challenge traditionally accepted notions of how governments...more
6/20/2017
/ Anti-Corruption ,
Antiboycott Requirements ,
Arbitration ,
Coast Guard ,
Customs and Border Protection ,
Export Administration Regulations (EAR) ,
Foreign Corrupt Practices Act (FCPA) ,
International Arbitration ,
Jones Act ,
Punitive Damages ,
Vessels
Any company doing business abroad is subject to the long reach of the Foreign Corrupt Practices Act (“FCPA”). Small or privately-held companies, just like large or public companies, are subject to the criminal specter of the...more