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Second Circuit Rejects DOJ’s Use of Conspiracy and Accomplice Liability to Prosecute Foreign Nationals for FCPA Violations

USA - August 29 2018 For years, the U.S. Department of Justice (DOJ) has taken the position that theories of conspiracy and aiding and abetting allow it to prosecute...

Ike Adams, Craig Francis Dukin, Leslie A. Shubert.


Top DOJ Official Announces New FCPA Policy for M&A Transactions

USA - August 2 2018 At an American Conference Institute event on July 25, 2018, Department of Justice (DOJ) Deputy Assistant Attorney General Matthew Miner announced the...

Ike Adams, Craig Francis Dukin, Leslie A. Shubert.


For Whom the SEC Tolls: A Recent Foreign Corrupt Practices Act Case Highlights the Importance of Language in Tolling Agreements

USA - July 20 2018 On July 13, a federal judge dismissed a U.S. Securities and Exchange Commission (SEC) lawsuit accusing two former executives of Och-Ziff Capital...

Jose F. Sanchez, Stephen L. Cohen, Julia G. Mirabella, Milton P. Wilkins, Fiona A.Philip.


New U.S. Department of Justice Policy on Coordination of Corporate Penalties

USA - June 7 2018 On May 9, 2018, Deputy Attorney General Rod Rosenstein announced a new policy that could have important consequences for corporate enforcement actions...

Kristin Graham Koehler, Karen A. Popp.


Notable Development in How Singapore Authorities Sanction Corporate Corruption Made Overseas

Singapore - February 15 2018 In what appears to be a first in Singapore, a conditional warning in lieu of prosecution was served on Keppel Offshore & Marine, a Singapore...

Nicholas Seng, Yuet Ming Tham.