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SAP Non-Prosecution Agreement Signals a New Standard for Compliance

USA - June 1 2021 On April 29, 2021, the Department of Justice (“DOJ”) announced that it had entered into a non-prosecution agreement (“NPA”) with SAP SE…

Gustavo J. Membiela, Sean B. O’Connell, Alexandra Taylor

New US Sanctions on Russia Target Certain Cyber Actors and Sovereign Debt

Russia, USA - April 26 2021 On April 15, 2021, President Biden issued an Executive Order imposing new sanctions on the Russian Federation citing election interference, malicious…

Sevren R. Gourley, Eric R. Markus, Gustavo J. Membiela, William L. Newton

DOJ Revises Guidance on Evaluation of Corporate Compliance Programs

USA - June 8 2020 What Happened: On Monday, June 1, 2020, the US Justice Department ("DOJ") published revised guidance on how it evaluates corporate compliance…

Kevin E. Gaunt, Ann E. Hancock

OFAC Provides Further Guidance on Reporting, Procedures and Penalties

USA - June 24 2019 What Happened: On June 20, 2019, the Department of Treasury's Office of Foreign Assets Control (OFAC) issued an interim final rule to amend the…

Kevin E. Gaunt, Natalia San Juan, Eric R. Markus, Gustavo J. Membiela

DOJ Announces New Guidelines for Awarding Cooperation Credit in the Resolution of False Claims Act Cases

USA - May 15 2019 What Happened: On May 7, 2019, the Department of Justice (DOJ) announced an amendment to the Justice Manual (previously the US Attorney's Manual or…

Eric H. Feiler, Mark S. Hedberg, Matthew D. Jenkins, James M. Pinna, Alexandra Taylor