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DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

The Foreign Corrupt Practices Act of 1977 (FCPA) makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. On November 29,...more

Alstom Guilty Plea Sends Strong Message that DOJ Has Harsh View of Inadequate Internal Controls and Failure to Fully Cooperate

On December 22, 2014, French power and transportation company Alstom S.A. (“Alstom”) pleaded guilty to violating the Foreign Corrupt Practices Act (“FCPA”) and agreed to pay $772.29 million, the largest criminal fine ever...more

The SEC Whistleblower Program

On Oct. 1, 2013, the Securities and Exchange Commission (SEC) announced that it had awarded more than $14 million to an unidentified whistleblower who provided information leading to a successful enforcement action — by far...more

Department of Justice Cites Poor Compliance Program and Lack of Cooperation in Extracting Significant FCPA Penalties in Marubeni...

The importance of a company’s response to a Department of Justice (“DOJ”) investigation into possible violations of the Foreign Corrupt Practices Act (“FCPA”) was highlighted last week when Marubeni Corporation (“Marubeni”)...more

The Foreign Corrupt Practices Act—A Look Back at 2012 and 2013

Over the last two years, enforcement of the Foreign Corrupt Practices Act (“FCPA”) has remained a priority of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”). That emphasis is likely to...more

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