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Compulsory Corporate Monitorships: Strategies for Success

Numerous regulatory jurisdictions internationally, as well as multiple nongovernmental organizations (NGOs) such as the World Bank, have increasingly used compulsory corporate monitorships as part of their respective...more

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more

Show Me the Money: Using Compensation Structures to Promote Compliance

Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

DOJ Announces New Mergers & Acquisitions Safe Harbor Policy for Voluntary Self-Disclosures

On October 4, Deputy Attorney General Lisa O. Monaco addressed the Society of Corporate Compliance and Ethics and announced a new Department-wide Mergers & Acquisition (M&A) Safe Harbor policy. According to the new policy,...more

JPMorgan Chase DPA Provides Insight into Government’s Assessment of Compliance Programs

On September 29, 2020, US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving...more

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