Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
In my final post of 2013, I reviewed all of the individual Foreign Corrupt Practices Act enforcement actions which occurred in the past year. In this first post of 2014, I review all the corporate enforcement actions in 2013....more
Last week I used the 150th anniversary of the Battle of Gettysburg as a prism to look at present day compliance issues. Today I want to go in a different direction to introduce today’s topic....more
Trying to avoid the unusually strict import controls in Argentina and facilitate faster clearance of its products through customs, a subsidiary of Ralph Lauren Corp. was found to have bribed local officials between 2005 and...more
Often, enforcement officials at the SEC and the Justice Department express their wish that securities law violators own up to their (mis)conduct as soon it comes to light. That is, come to the government and explain what has...more