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Corruption Willful Misconduct

Porter Hedges LLP

New Action By The CFTC Means Higher Stakes For Commodity Market Participants

Porter Hedges LLP on

The Commodity Futures Trading Commission (“CFTC”) recently announced the settlement of its first enforcement action involving foreign corruption. In December 2020, the CFTC issued a Consent Order, finding that Houston-based...more

Vinson & Elkins LLP

Data Corruption: DOJ Targets Fraud In Medical Research Trial In The Era Of COVID-19

Vinson & Elkins LLP on

In late 2019, Gustav Eyler, the Director of the U.S. Department of Justice’s (“DOJ”) Consumer Protection Branch (“CPB”), cited fraudulent data in clinical research trials for new drugs and medical devices as a topic of “major...more

Ballard Spahr LLP

Federal Court Makes Clear That International Financial Institution Must Appear for Arraignment in Criminal Action

Ballard Spahr LLP on

Court Rejects Attempt by Halkbank to Enter “Special Appearance” Contesting Jurisdiction - Turkish state-owned bank Halkbank’s efforts to avoid appearing in U.S. federal court for arraignment were squashed recently in a...more

Kramer Levin Naftalis & Frankel LLP

DOJ Announces More Lenient Corporate Cooperation Policy

In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more

Ballard Spahr LLP

The BSA Civil Penalty Regime: Reckless Conduct Can Produce “Willful” Penalties

Ballard Spahr LLP on

Conduct Performed Without Knowledge Still Can Lead to the Most Serious Penalties - Under the Bank Secrecy Act (“BSA”), the most onerous civil penalties will be applied for “willful” violations....more

Burr & Forman

Deflategate’s Lessons for Civil Arbitrations

Burr & Forman on

Unless you live under a rock, you’ve heard about “Deflategate:” The Patriots’ use of allegedly under-inflated footballs during their 45-7 win over the Colts in last-year’s AFC Championship. In a 40-page opinion issued...more

King & Spalding

DOJ Hires Compliance Counsel to Assist in Charging Decisions

King & Spalding on

New Compliance Counsel Will Assess Effectiveness of Corporate Compliance Programs - Last week the U.S. Department of Justice (DOJ) revealed it is hiring a compliance counsel to assist DOJ prosecutors in assessing the...more

The Volkov Law Group

Mead Johnson: Baby Formula and Bribes

The Volkov Law Group on

Last week, the SEC announced a settlement of an FCPA enforcement action for $12 million against Mead Johnson Nutrition for payment of bribes in China to health care professionals at state-owned hospitals. Mead Johnson’s...more

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