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Juniper FCPA Settlement Provides Useful Compliance Reminders
On August 29, 2019, the Securities and Exchange Commission ("Commission" or "SEC") agreed to resolve an enforcement action against Juniper Networks, Inc.
United States
6 Sep 2019
DOJ Issues Updated Guidance On Evaluation Of Corporate Compliance Programs
On April 30, 2019, the Assistant Attorney General for the Criminal Division, Brian A. Benczkowski, announced an update to the DOJ's 2017 guidance document entitled Evaluation of Corporate Compliance Programs.
United States
6 Jun 2019
Global Anti-Bribery Year-In-Review: 2018 Developments And Predictions For 2019
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year—2018 was yet again an active year for FCPA enforcement.
United States
21 Jan 2019
DOJ Announces Revisions To Policy On Corporate Cooperation
In a November 29, 2018 speech,1 Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice's (DOJ) policy on giving credit for cooperation in corporate prosecutions.
United States
11 Dec 2018
DOJ Announces New Policy On Assessing The Need For And Selection Of Corporate Monitors
This change, as well as specifics from the new 2018 Monitor Memorandum, are detailed below.
United States
18 Oct 2018
Second Circuit Limits Government's Ability To Prosecute Foreign Persons And Companies For Conspiracy To Violate The FCPA
On August 24, 2018, the United States Court of Appeals for the Second Circuit issued a significant ruling regarding the reach of the FCPA over foreign companies and individuals in United States v. Hoskins, No. 16-CR-1010.
United States
29 Aug 2018
SEC Settles Enforcement Action Against Beam Suntory for Improper Payments by Its Foreign Subsidiary
On July 2, 2018, the Securities and Exchange Commission (Commission or SEC) settled an enforcement action against Beam Suntory Inc. (Beam), a worldwide beverage maker and distributor, over alleged violations of the Foreign Corrupt Practices Act (FCPA) related to improper payments by its Indian subsidiary, Beam Global Spirits & Wine (India) Private Limited (Beam India).
United States
16 Jul 2018
New DOJ Policy To Prevent "Piling-On"
On May 9, 2018, Deputy Attorney General Rod J. Rosenstein introduced a new Department of Justice Policy on Coordination of Corporate Resolution Penalties while speaking at the New York City Bar White Collar Crime Institute.
United States
31 May 2018
New DOJ FCPA Enforcement Policy Raises Difficult Questions For Companies Considering Voluntary Disclosures
This article highlights a few of the uncertainties and potential pitfalls that may await a company deciding whether to take the significant step of voluntarily disclosing criminal conduct to prosecutors.
United States
19 Feb 2018
Global Anti-Bribery Year-In-Review: 2017 Developments And Predictions For 2018
This past year marked the 40th anniversary of the FCPA. Since its enactment in 1977, the DOJ has brought approximately 300 FCPA enforcement actions, while the SEC has brought approximately 200 cases.
United States
15 Jan 2018
Global Magnitsky Sanctions Target Human Rights Abusers And Government Corruption Around the World
On December 20, 2017, President Trump issued a new Executive Order (EO) targeting corruption and human rights abuses around the world.
United States
28 Dec 2017
DOJ Announces New FCPA Corporate Enforcement Policy
Today, "[d]ue to the unique issues presented in FCPA matters," Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys' Manual.
United States
30 Nov 2017
Evaluating FCPA Pilot Program: Lessons And Expectations
On April 5, 2016, the U.S. Department of Justice released a nine-page memorandum launching a one-year pilot program to reward companies that voluntarily self-report violations of the Foreign Corrupt Practices Act.
United States
21 Apr 2017
DOJ Launches FCPA Pilot Program to Encourage Corporate Voluntary Disclosure and Cooperation
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act (FCPA) enforcement, ..
United States
11 Apr 2016
Busy 1st Quarter For FCPA Enforcement
Recent actions announced by the U.S. Department of Justice and the U.S. Securities and Exchange Commission during the first quarter of 2016 suggest that this year may be a significant one for Foreign Corrupt Practices Act enforcement.
United States
1 Apr 2016
Busy Q1 Yields Several Significant FCPA Resolutions
Recent actions announced by the DOJ and SEC during the first quarter of 2016 suggest that this year may be a significant one for FCPA enforcement.
United States
30 Mar 2016
Global Anti-Bribery Year-In-Review: 2015 Developments And Predictions For 2016
Among other significant developments, 2015 saw the U.S. Department of Justice (the "DOJ" or the "Department") document a policy priority of holding individuals accountable for corporate wrongdoing.
United States
3 Feb 2016
Federal Judge Rejects DOJ's Theory Of FCPA Accomplice Liability
On August 13, 2015, a US district judge dismissed a charge seeking to hold a defendant criminally liable for conspiracy to violate the Foreign Corrupt Practices Act (FCPA) if he is not a principal or agent of a US domestic concern and did not physically enter US territory.
United States
3 Sep 2015
Global Anti-Bribery Year-in-Review: 2014 Developments and Predictions for 2015
The year 2014 witnessed several notable developments in the enforcement of the Foreign Corrupt Practices Act (FCPA).
28 Jan 2015
Eleventh Circuit Adopts Broad Definition Of Government "Instrumentality" Under FCPA
The Eleventh Circuit affirmed a broad definition of "instrumentality" of a foreign government, as the term is used in the Foreign Corrupt Practices Act.
United States
27 May 2014
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