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Searching Content by James Dowden from Ropes & Gray LLP ordered by Published Date Descending.
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New DOJ Guidance Reflects An Evolution In The Evaluation Of Corporate Compliance Programs
On April 30, 2019, the DOJ's Criminal Division published an updated Evaluation of Corporate Compliance Programs Guidance Document ("the Guidance") for prosecutors to use in evaluating corporate compliance programs.
United States
17 May 2019
2
Second Circuit Holds That FCPA Does Not Apply To Foreigners Without U.S. Ties
On August 24, 2018, the United States Court of Appeals for the Second Circuit ruled that a non-resident foreign national cannot be charged with conspiracy to violate the Foreign Corrupt Practices Act ...
United States
29 Aug 2018
3
DOJ Commentary Underscores The Importance Of Pre-Acquisition Diligence
These statements were consistent with the DOJ's continuing efforts to provide clearer guidance and more consistent outcomes in FCPA enforcement.
United States
6 Aug 2018
4
Rosenstein Announces Permanent FCPA "Pilot Program," Presumption Of Declination When Self-Reporting, But Difficult Choices Remain
Recent statements by the Co-Director of the SEC's Enforcement Division indicate that the SEC has not emphasized individual prosecutions to the same degree as DOJ.
United States
5 Dec 2017
5
$519 Million FCPA Payment By Teva Pharmaceuticals—Largest Ever FCPA Payment By Pharmaceutical Company—Follows Large FCPA Plea Agreement With Obedrecht And Braskem
On December 22, 2016, the world's largest manufacturer of generic pharmaceuticals, Teva Pharmaceuticals, agreed to pay $519 million in FCPA-related criminal penalties, disgorgement, and interest.
Worldwide
29 Dec 2016
6
Anti-Corruption Laws And Other International Risks – What It Means For The Real Estate Industry And How To Protect Against Risks
Bribery, money laundering, and sanctions are key international risk areas for any global business, particularly those investing or operating in high-risk jurisdictions and industries.
United States
12 Aug 2016
7
Federal Jury Acquits Former Warner Chilcott President
Reichel's acquittal follows the company's October 2015 guilty plea in which it admitted to crimes in connection with sales force misconduct.
United States
23 Jun 2016
8
DOJ Issues Guidance On Individual Accountability For Corporate Misconduct
Under this new guidance, corporations have an enhanced responsibility to provide information to DOJ about individual misconduct in order to be eligible to receive credit for cooperating with a DOJ investigation.
United States
14 Sep 2015
9
SEC Charges Australian Mining Company For FCPA Violations Arising From Its Hospitality Program At The 2008 Beijing Olympics
On May 20, 2015, the U.S. Securities and Exchange Commission ("SEC") announced a $25 million settlement with Australian mining company BHP Billiton (the "Company") to resolve Foreign Corrupt Practices Act ("FCPA") charges arising from the Company's sponsorship of the 2008 Summer Olympics
United States
22 May 2015
10
Court Issues Rare Guidance On When State-Owned Enterprises Are ‘‘Instrumentalities’’ Of Foreign Governments
The Eleventh Circuit set forth a test for evaluating when the executives and employees of a company owned by a government constitute ''foreign officials''.
United States
17 Jul 2014
11
Foreign Corrupt Practices Act Enforcement Activity: 2013 Year In Review And 2014 Preview
The 2013 calendar year saw several significant developments in the enforcement of the Foreign Corrupt Practices Act.
United States
31 Mar 2014
12
SEC Enters Into First Deferred Prosecution Agreement With An Individual
The U.S. Securities and Exchange Commission ("SEC" or "Commission") announced on Tuesday that it entered into its first Deferred Prosecution Agreement ("DPA" or "Agreement") with an individual in connection with a possible enforcement action.
United States
16 Nov 2013
13
Fourth Circuit Oral Argument Considers Questions Concerning Constitutionally Problematic FCA Fines
The Fourth Circuit recently heard oral argument in United States ex rel. Bunk v. Gosselin World Wide Moving.
United States
18 Jun 2013
14
Government Enforcement Attorneys Analyze Amendments To Insider Trading Sentencing Guidelines And Appropriate Compliance
Government enforcement partners Chris Conniff (New York) and Jim Dowden (Boston), and securities litigation associate Brendon Carrington have written "Insider Trading Sentences Get Extra Bite" for the May 7 issue of Compliance Reporter.
United States
4 Dec 2012
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