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PdVSA Sanctions Designation Has Significant Implications for US Business

USA - February 14 2019 On January 28, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the Venezuelan state-owned oil company...

Edward J. Krauland, Evan Abrams, Jack R. Hayes, Brian Egan, Jillian Norton, Meredith Rathbone, Peter Edward Jeydel.

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, Lucinda A. Low, Brittany Prelogar.

Sportsmanlike Conduct? DOJ Announces Policy to Avoid ‘Piling On’ Monetary Sanctions in Corporate Resolutions

USA - May 14 2018 On May 9, 2018, in remarks made at the American Conference Institute’s 20th Anniversary New York Conference on the Foreign Corrupt Practices Act...

Bo Yue, Elizabeth Arkell, 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, Lucinda A. Low.

2017 FCPA Mid-Year Review

USA - June 29 2017 2017 began with a flurry of enforcement actions in the first weeks of January, including some major resolutions that broke new ground in international...

Brady Cassis, Claire Blakey, Sara Chouraqui, Lucinda A. Low, Brittany Prelogar, Helen Aldridge, Patrick Rappo, Pablo M. Bentes, Brigida Benitez.