Deciding to self-disclose is one thing; doing it well is another, and the difference often shapes whether a company earns credit or invites a harder look. Sean M. Farrell and Thomas F. Rybarczyk of Kelley Drye, both former federal prosecutors, walk through what an effective disclosure would look like under the DOJ's corporate enforcement policy.
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In April, a bipartisan coalition of 34 state attorneys general won a landmark jury verdict against Live Nation — after the DOJ settled its own case mid-trial. Weeks earlier, a separate multistate coalition persuaded a court to block the Nexstar-Tegna merger that federal regulators had already cleared. Michelle Mantine, who leads the antitrust & competition team at Reed Smith, spoke with CCI about what cases like these signal for companies that have built their compliance programs around federal enforcement priorities — and why
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False Claims Act recoveries and whistleblower numbers point to something deeper than individual enforcement actions. The experts CCI contributing writer...
The debut book by legal historian Severin Wirz, “Bribery Beyond Borders: The Story of the Foreign Corrupt Practices Act,” is a timely reexamination of the statute’s Cold War origins and modern-day relevance. Published by CCI Press, Wirz’s book arrives as the FCPA nears its 50th anniversary and faces renewed scrutiny from reformers, regulators and multinational corporations alike.
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Of the nine enforcement cases CCI examined where companies received credit for timely disclosure, only two included a measurable time...
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The first under the new policy shows what companies stand to gain and what they need to have in place...
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