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Enforcement Actions Cooperation Initiative

Hogan Lovells

DOJ refines cooperation requirements of FCPA corporate enforcement policy

Hogan Lovells on

On November 20, 2019, the U.S. Department of Justice (DOJ) announced several subtle, but important, adjustments to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. These recent changes relate to...more

Jones Day

FINRA Clarifies When Credit for Extraordinary Cooperation Will Be Awarded in Investigations

Jones Day on

The Situation: In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority ("FINRA") on what constitutes "extraordinary" cooperation with its investigations and when...more

A&O Shearman

Companies With Effective Antitrust Compliance Programs Could Get Relief From Criminal Prosecution Under New DOJ Policy

A&O Shearman on

The Antitrust Division of the U.S. Department of Justice (Division) finally will consider the existence of effective antitrust compliance programs at the charging stage of criminal antitrust investigations, opening up the...more

Hogan Lovells

The Antitrust Division changes the calculus for cooperating cartelists

Hogan Lovells on

Change is here. A few weeks ago, Makan Delrahim – Assistant Attorney General for the Antitrust Division of the U.S. Department of Justice (the Division or DOJ) – signaled a major change in how the Division will assess a...more

The Volkov Law Group

International Coordination and Cooperation in Corruption Cases

The Volkov Law Group on

Global anti-corruption enforcement is fast becoming a complicated affair. No longer can companies just focus on the FCPA, with momentary blips of concern for the UK Bribery Act....more

Brownstein Hyatt Farber Schreck

SEC Cooperation Agreements: With the Right Approach, Potentially a Valuable Tool for Those Facing Sanctions

Brownstein Hyatt Farber Schreck attorneys recently worked with staff in the Denver Regional Office of the U.S. Securities and Exchange Commission (“SEC”) to negotiate both a proffer agreement and a cooperation agreement on...more

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