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Steptoe & Johnson LLP | USA | 6 Dec 2017

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

As we discussed in last week’s blog post, on November 29, 2017, Deputy Attorney General Rod J. Rosenstein made remarks at the American Conference


Skadden Arps Slate Meagher & Flom LLP | USA | 30 Nov 2017

DOJ Announces Revised FCPA Corporate Enforcement Policy

In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced


Steptoe & Johnson LLP | USA | 30 Nov 2017

Deputy Attorney General Rosenstein Announces Significant New FCPA Corporate Enforcement Policy

Yesterday, in remarks made at the 34th International Conference on the FCPA, Deputy Attorney General Rod J. Rosenstein recognized the success of the


Holland & Knight LLP | USA | 29 Nov 2017

DOJ Makes Permanent Its Program to Incentivize Self-Disclosure in FCPA Investigations

The U.S. Department of Justice's (DOJ) pilot program established in 2016 to incentivize companies to self-report violations of the Foreign


Jones Day | USA | 1 Nov 2017

DOJ's New FCPA Enforcement Policy Continues its "Carrot-and-Stick" Approach

The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty


Jones Day | USA | 1 Aug 2017

Yates Memo's Influence Felt in DOJ Health Care Enforcement

Almost two years after Sally Yates, then Deputy Attorney General, issued a memorandum regarding individual accountability for corporat


Jones Day | USA, United Kingdom, European Union, etc. | 1 Jun 2017

Global Privacy & Data Security Update Vol. 14

On March 21, 2017, the New York Attorney General's Office announced that it received 1,300 reported data breaches in 2016a 60 percent increase from


Morrison & Foerster LLP | USA, Australia, United Kingdom | 30 May 2017

Top Ten International Anti-Corruption Developments for April 2017

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international


Thompson Coburn LLP | USA | 26 May 2017

Trending Wonkology: What is 'Special Counsel'?

Prior to Watergate, there was no formal process or requirement for the appointment of special counsel. As a result, appointments were ad hoc. Special


Bryan Cave Leighton Paisner (Bryan Cave) | USA | 23 May 2017

Special Counsels in U.S. Government

Appointments of "special counsels" in the United States government are historically very rare and only called upon to investigate politically

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