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DOJ Assistant AG Benczkowski Discusses Use of Agency Liability Theory in FCPA Prosecutions

Assistant Attorney General Brian Benczkowski delivered remarks on December 4 at the American Conference Institute’s 36th International Conference on the Foreign Corrupt Practices Act. AAG Benczkowski addressed the US...more

DOJ to Business: We Are Your Partners Not Adversaries

Highlighting the accomplishments and developments at the US Department of Justice (DOJ) over the past 12 months, Deputy Assistant Attorney General Matthew Miner urged the business sector to work cooperatively with the DOJ and...more

No Accomplice, Conspiracy Liability for Certain Foreign Nationals in FCPA Crimes

In a decision that is likely to resonate across various US government enforcement efforts, the US Court of Appeals for the Second Circuit recently ruled that the Foreign Corrupt Practices Act does not apply to nonresident...more

US Deputy Assistant Attorney General Reinforces Importance of Transparency in M&A Compliance Programs

US Deputy Assistant Attorney General Matthew S. Miner recently delivered remarks at a forum on anti-corruption compliance, where he highlighted the Department of Justice’s growing efforts to increase transparency between DOJ...more

DOJ Announces New ‘No Piling-On’ Policy, but Maintains Compliance Expectations

The US Department of Justice announced on May 9 a new policy to avoid the imposition of duplicative penalties by multiple authorities in corporate fraud investigations. But, the DOJ’s expectations with respect to compliance...more

Compliance as a Valuable Tool for Avoiding Enforcement Action in Mexico and Latin America

The Recent Focus on Corruption in Mexico - On July 19, 2017, the General Law of Administrative Responsibilities (GLAR) went into effect in Mexico, making it a “serious administrative offense” for individuals and companies...more

Significant Changes In Anti-Bribery Laws In Mexico And Colombia Signal A New Commitment To Anti-Corruption Efforts

For companies with global operations, the Foreign Corrupt Practices Act (FCPA) is no longer the only anticorruption law of significance. Mexico and Colombia recently enacted sweeping anti-corruption legislation aimed at...more

DOJ Issues New Guidance on Corporate Compliance Programs

The DOJ Fraud Section’s “Evaluation of Corporate Compliance Programs” puts chief compliance officers on notice about how the adequacy of their companies’ compliance programs is evaluated by prosecutors....more

DOJ Issues New FCPA Guidance and Launches Self-Reporting Pilot Program

The US Department of Justice has announced the creation of a one-year pilot program intended to encourage companies to self-report bribery violations and provide extensive cooperation in exchange for reduced penalties,...more

DOJ Quietly Revises FCPA Resource Guide

Revisions bring DOJ and SEC guidance in line with FCPA statutory language. In June, the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) quietly revised its manual, A Resource Guide to the U.S....more

FBI Establishes “Dedicated International Corruption Squads” to Bust FCPA Violators

The squads will extend the capabilities of the US Department of Justice and the US Securities and Exchange Commission to gather evidence and enforce the Foreign Corrupt Practices Act....more

Brazil Enacts Anti-Corruption Law

Companies doing business in the country should evaluate their compliance programs to avoid the law's sanctions on violators. On August 2, Brazilian President Dilma Rousseff signed Law No. 12,846/2013—unofficially...more

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