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Second Circuit Reinforces FCPA’s Jurisdictional Limits

Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties. Key Points: ..Non-resident foreign nationals who are not otherwise subject to direct...more

New DOJ Policy Will Curb “Piling On” Multiple Penalties for Same Corporate Misconduct

Corporate resolution policy will provide greater clarity and predictability for companies that self-report and cooperate with DOJ. Key Points: ..The new policy requires DOJ civil and criminal prosecutors to coordinate...more

Deputy Attorney General Announces Comprehensive Review of DOJ Corporate Enforcement Policies

Key Points: - DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors. - Policies will be codified in official...more

Expanding FIRREA Liability for Financial Institutions: Recent Second Circuit Developments

In a brief — and swiftly decided — per curiam decision issued June 4, 2015, the US Court of Appeals for the Second Circuit affirmed the wire fraud and wire fraud conspiracy convictions of three former UBS Financial Services,...more

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