The FCPA and Fight Against Terrorism
I admit it took me awhile to finally get it. I have long wondered what could have caused the explosion ...
Tag: Tone at the Top
Code Violations, Enforcement and “Broken Windows”
Sometimes our experiences provide important lessons that we can apply in our current jobs. While I served as a federal ...
When to Use Outside Counsel for FCPA Investigations
These days, more and more companies are developing internal resources to manage potential FCPA violations.
Ukraine Update: Anti-corruption Legislation Amid the Protests
The most significant element in the legislation is the introduction of corporate criminal liability for companies whose employees or their ...
Follow the Bouncing Ball – Tracking DOJ Investigations
Looking back on 2013, the Department of Justice and SEC had a strong enforcement year. It is interesting to analyze ...
The FCPA in 2013: The Year in Review
2013 was a significant year in FCPA enforcement. Both the Department of Justice and Securities and Exchange Commission continued to ...
Each Case is Unique – Drawing Lessons from Opinion Release 13-01
SEC and DOJ look at the facts and circumstances around each case in making assessments. While this is frustrating to ...
G8 Open Data Charter – The Implications for Due Diligence
One of the more substantial outcomes of the recent G8 leaders’ summit was the signing of the Open Data Charter.
Voluntary Disclosures, through the Eyes of FCPA Enforcement
When James Cole, U.S. Deputy Attorney General, gave his keynote address at ACI’s 30th International Conference on the FCPA, he ...
Supermarket to the World – The ADM FCPA Enforcement Action
Last week, it was announced that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) had settled an ...
