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What’s New—Key Updates to the DOJ and SEC’s FCPA Resource Guide

For the first time since its original publication in November 2012, on July 3, 2020, the U.S. Department of Justice (“DOJ”) Criminal Division and the U.S. Securities and Exchange Commission (“SEC”) published substantive...more

DOJ Rolls Out Incentive Structure for Self-Reporting Civil FCA Violations

Earlier this week, the Department of Justice issued “Guidelines for Taking Disclosure, Cooperation, and Remediation into Account in False Claims Act Matters” (the FCA Guidelines), intended to incentivize self-disclosure,...more

DOJ’s Quiet Changes to the FCPA Corporate Enforcement Policy Likely to Have a Significant Impact on Corporate Investigations

As the annual ABA White Collar Crime Conference wrapped up in New Orleans last Friday night, the Department of Justice released the latest updates to its FCPA Corporate Enforcement Policy. The key changes to the policy...more

Key Takeaways from Cognizant Technology’s Improbable Receipt of a Declination from DOJ

Last week, in what marked the first FCPA enforcement action of 2019, a federal grand jury in New Jersey returned an indictment against two former high-level executives—the president and chief legal officer—of Cognizant...more

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