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The Year 2015 in Anti-Bribery Enforcement: Are Companies in the Eye of an Enforcement Storm?

Brazil, China, France, Germany, OECD, Russia, United Kingdom, USA - January 26 2016 While one year’s statistics do not, standing alone, make trends, several things about anti-bribery enforcement in 2015 are inescapable. In the United…

David A. O'Neil, Dmitri V. Nikiforov, Dr. Thomas Schürrle, Paul R. Berger, Sean Hecker.

The SEC’s Most-Recent Nudge to Self-Report: Will it Make a Difference?

USA - December 22 2015 In recent months, senior leaders of the U.S. Department of Justice (“DOJ”) have garnered significant headlines by publicizing a renewed focus on…

Bruce E. Yannett, Paul R. Berger, Sean Hecker, Steven S. Michaels.

Brazil issues guidelines for compliance programs

Brazil - October 29 2015 On September 22, 2015, Brazil’s Comptroller‑General of the Union (the “CGU”) issued guidelines (the “Guidelines”) on framing and implementing…

Bernardo Becker Fontana, Daniel Aun, Sean Hecker, Steven S. Michaels.

No coverage under commercial general liability policies in recent data privacy suits

USA - October 13 2015 Two federal courts recently held that, under commercial general liability ("CGL") policies, insurance companies did not owe policyholders a duty to…

Jeewon Kim Serrato, Jeremy Feigelson, Keith J. Slattery, Sisi Wu.

D.C. Circuit again issues mandamus to protect internal investigation documents

USA - August 28 2015 The U.S. Court of Appeals for the D.C. Circuit has once again stepped into an ongoing fight between the proponent of a qui tam action and Kellogg…

Colby A. Smith, Johanna N. Skrzypczyk.