Employers will not be able to take full advantage of the DOJ’s new program if their compensation systems do not permit clawbacks from wrongdoer employees. Companies should review their existing compensation systems and...more
In 2012, Donald Trump called the Foreign Corrupt Practices Act (“FCPA”) “ridiculous” and a “horrible law” that made it more difficult for U.S. companies to compete abroad. While President Trump’s private thoughts on the FCPA...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
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
Action Item: The U.S. Department of Justice Criminal Division, Fraud Section (“DOJ”), recently published new guidance on corporate compliance programs. All corporate counsel, officers, and directors should be aware of this...more
On July 28, 2014, Smith & Wesson Holding Corp. (“Smith & Wesson”), the firearms manufacturer based in Springfield, Massachusetts, agreed to resolve charges brought by the Securities and Exchange Commission (“SEC”) for...more