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DOJ Revamps Corporate Compliance Program Guidance, Broadens Application

USA - May 9 2019 On April 30, 2019, the US Department of Justice (DOJ) Criminal Division announced the publication of updated Guidance on Evaluating Corporate...

Jessica Piquet Megaw, Brittany Prelogar, Patrick F. Linehan, Rachel B. Peck.

Long-Awaited Decision Issued on FCPA’s Reach Over Non-Resident Foreign Nationals

USA, OECD - September 5 2018 On August 24, 2018, the US Court of Appeals for the Second Circuit rejected an effort by the Department of Justice (DOJ) to expand the jurisdictional...

Ronak D. Desai, Tom Best, Brittany Prelogar.

FCPAAnti-Corruption Developments: 2017 Year in Review & Q1 2018 Preview

USA - April 12 2018 2017 was a year of transition for US enforcement of the Foreign Corrupt Practices Act (FCPA) and saw a significant increase in global anti-corruption...

Richard K. Wagner, William L. Drake, Simon Hirsbrunner, Alexandra E.P. Baj, Brittany Prelogar, Patrick Rappo, Pablo M. Bentes, Jeffrey W. Cottle, Brigida Benitez.

The DOJ’s New FCPA Corporate Enforcement Policy: Dangling Presumptive Declination as an Incentive for Voluntary Disclosure

USA - December 4 2017 On November 29, 2017, in remarks made at the American Conference Institute's 34th International Conference on the Foreign Corrupt Practices Act (FCPA)...

Jessica Piquet Megaw, Brittany Prelogar.

In the Wake of Kokesh v. SEC: Whither Disgorgement in FCPA Cases

USA - July 13 2017 On June 5, 2017, the United States Supreme Court unanimously held in Kokesh v. Securities and Exchange Commission 1 that disgorgement in SEC...

Jessica Piquet Megaw, Tom Best.