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Corruption Recidivism

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Steps Up Corporate Criminal Enforcement, Looks More Broadly at Past Misconduct

Takeaways - The DOJ will take a more proactive approach to FCPA investigations. Companies seeking cooperation credit must disclose information about all culpable individuals, not just those “substantially involved” in...more

Thomas Fox - Compliance Evangelist

Stryker FCPA Enforcement Action: Compliance Lessons For Distributors and Dealers – Part II

Over this two-part blog post series, I have been considering the Stryker Corporation 2018 Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

Stryker FCPA Enforcement Action: Compliance Lessons For Distributors and Dealers – Part I

Last month, Stryker Corporation joined a rather ignominious list of recidivists under Foreign Corrupt Practices Act (FCPA) enforcement annuls....more

The Volkov Law Group

Stryker Suffers “Strike Two” and Settles SEC FCPA Case

The Volkov Law Group on

Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.” In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now...more

The Volkov Law Group

Defining Deterrence in White Collar Crime Cases (Part III of III)

The Volkov Law Group on

There are two types of deterrence – specific and general. Specific deterrence focuses on the risk of recidivism by the individual defendant. General deterrence is focused on preventing others from engaging in similar...more

The Volkov Law Group

FCPA Recidivists: Orthofix (Part II of II)

The Volkov Law Group on

In its continuing quest to push the message of aggressive FCPA enforcement, the SEC resolved FCPA charges against Orthofix, a medical device company, for $6 million in penalties and disgorgement. In a related action, the SEC...more

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