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New DOJ FCPA Guidelines Target Cases Linked to US Strategic Interests

On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more

Keep Calm and Carry On: Thoughts on Recent Orders on FCPA Enforcement

What in the world is happening with enforcement of the Foreign Corrupt Practices Act (FCPA)? And what does the recent executive order (EO) and Department of Justice (DOJ) guidance mean for U.S. and global companies? Our view...more

Off to the Races: DOJ Offers New Incentives for Whistleblowers and Companies to Report Misconduct

Earlier this year, as described in a previous client alert, the Department of Justice (“DOJ”) Criminal Division announced a landmark pilot program to pay monetary awards to whistleblowers (the “Program”). At that time, Deputy...more

Recent Whistleblower Activity Increases Pressure on Internal Reporting and Investigation Mechanisms

On May 5, 2023, the Securities and Exchange Commission (“SEC”) granted its largest-ever whistleblower award of $279M to an individual, reportedly stemming from Ericsson’s $1.1B settlement to resolve claims that the...more

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