Life with GDPR - The ABB Enforcement Action from a UK Perspective
As we wrote earlier this month, the Department of Justice (DOJ) made significant news at the recent American Bar Association White Collar Conference. But the Department didn’t stop at announcing its pilot whistleblower...more
The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
On October 17, 2023, the Commodity Futures Trading Commission’s (“CFTC” or “Commission”) Division of Enforcement (“DOE”) released its latest enforcement advisory, providing guidance to CFTC staff on resolution of an...more
On October 4, 2023, Deputy U.S. Attorney General Lisa O. Monaco announced that the United States Department of Justice (DOJ) is implementing a new nationwide Mergers & Acquisitions Safe Harbor Policy (the “M&A Policy”)....more
On October 17, 2023, during a speech at the Program on Corporate Compliance and Enforcement held at the New York University School of Law, the Commodity Futures Trading Commission (CFTC) Director of Enforcement, Ian McGinley,...more
On January 17, 2023, Assistant Attorney General (AAG) Kenneth A. Polite, Jr. delivered remarks to an audience at the Georgetown University Law Center, announcing changes to the Criminal Division’s Corporate Enforcement Policy...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
Jonathan Armstrong and I return for another episode of the award-winning Life with GDPR. This episode discusses the recent ABB Foreign Corrupt Practices Act resolution. Jonathan considers the ABB enforcement action from the...more
In announcing recent changes to its corporate criminal enforcement policies, the Department of Justice (“DOJ” or the “Department”) continued its forceful “tough on crime” initiatives to deter wrongdoing....more
Late last week, the Department of Justice’s Deputy Attorney General, Lisa Monaco, announced several new guidelines for prosecutors to use when determining how to assess and treat corporate offenders....more
Discussion with two former senior prosecutors on how to handle cases involving Japanese multinational corporations - It is not unusual for the U.S. Department of Justice to investigate non-U.S. multinational corporations...more
The Commodities Futures Trading Commission (CFTC) and the National Futures Association (NFA) have outlined a broad enforcement agenda that aims to address recent commodities marketplace trends....more
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
The United States comprises about 4% of the world’s population – and houses about 22% of the world’s prison population. The U.S. Department of Justice reports that each year approximately 650,000 people are released from...more
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
Recidivist behavior is something that the US government is forced to face in Foreign Corrupt Practices Act (FCPA) enforcement from time-to-time. When a company agrees to a Deferred Prosecution Agreement (DPA) or...more