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Corruption Enforcement Actions Government Investigations

Latham & Watkins LLP

President Trump Issues Executive Order Pausing Foreign Corrupt Practices Act Enforcement at DOJ

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The order pauses new FCPA criminal cases, directs review of existing cases, and leaves open several questions, including implications for specific business sectors and civil enforcement....more

Zuckerman Spaeder LLP

The Meaning of Corruption (Revisited): United States v. Robertson and Further Considerations for White Collar Practitioners from...

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A previous post examined interpretations of the statutory term “corruptly” in case law arising from prosecutions of participants in the January 6, 2021 Capitol riot. A significant new case from the D.C. Circuit, United...more

The Volkov Law Group

Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of...

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If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class.  Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more

BCLP

Fallout from the Glencore resolutions & lessons learned

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On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more

Polsinelli

Another Wave of Criminal Charges Brought in COVID-Related Fraud

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The Department of Justice and the US Attorney offices around the country are continuing to be in hot pursuit of cases of fraud related to the COVID-19 pandemic. On April 20, 2022, the Department of Justice announced a new...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act

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Dive into the history and current state of the Foreign Corrupt Practices Act with Joseph DeMaria, a Fox Rothschild partner and former federal prosecutor, and Matthew Adams, Co-Chair of the White-Collar Criminal Defense &...more

WilmerHale

2021 Global Anti-Bribery Year-in-Review

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In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward...more

The Volkov Law Group

2022 FCPA Predictions

The Volkov Law Group on

This was a strange year.  Not just because of the continuing pandemic and economic disruption. The Biden Administration took over after an unusual and delayed transition. The apparatus of government was slow to transition....more

Proskauer Rose LLP

White Collar Crime Investigation & the Biden Administration

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In 2015, then-Deputy Attorney General Sally Yates issued a memorandum to the attorneys of the Justice Department articulating departmental policy on corporate misconduct. This memo became popularly known as the Yates Memo. It...more

The Volkov Law Group

Justice Department, HHS-OIG and Defense Investigators Bring Flurry of False Claims Act Cases (Part I of V)

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The False Claims Act is a powerful enforcement tool.  The Justice Department with its partner agencies are ramping up enforcement efforts.  The Biden DOJ is preparing to implement an aggressive FCA program across healthcare,...more

Polsinelli

Two Week Old DOJ COVID-19 Fraud Task Force Announces First Wave of Prosecutions—Many More Are Likely On The Horizon

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Last week, in light of the Department of Justice’s newly-formed COVID-19 Fraud Enforcement Task Force, we cautioned that COVID-related prosecutions were likely imminent. And on the heels of this DOJ task force, we are already...more

Ballard Spahr LLP

DOE Signals Renewed Commitment to Enforcement of Foreign Gift Reporting Requirements

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The U.S. Department of Education (DOE) recently announced that it is launching an investigation into the foreign gifts reporting practices of two higher education institutions. ...more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

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In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more

Polsinelli

DOJ’s False Claims Act Recoveries Rise to More Than $3 Billion in FY2019, With Continued Emphasis on Health Care Fraud Cases

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On January 9, 2020, the Civil Division of the U.S. Department of Justice (DOJ) announced that it recovered over $3 billion from civil False Claims Act (FCA) judgments and settlements in the fiscal year ending September 30,...more

The Volkov Law Group

Juniper Networks Settles FCPA Violations with SEC for $11.7 Million

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Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China. Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil...more

Polsinelli

Telemedicine Enforcement

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Telemedicine permits two-way, real time interactive communication between health professionals and patients. Its recent expansion has dramatically improved patient health by providing new access to health care for rural...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action-Lessons Learned

We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more

Hogan Lovells

U.S. and Brazilian Authorities Reportedly Cooperating in Investigation of Alleged Bribery and Price Fixing Related to Medical...

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In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more

Troutman Pepper Locke

DOJ as Your Ally: Government Weighs In on Patient Support Services Kickback Claims

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On December 17, the U.S. Department of Justice, in an unprecedented application of its statutory authority under section 3730(c)(2)(A) of the False Claims Act, moved to dismiss 11 qui tam complaints pending in district courts...more

Herbert Smith Freehills Kramer

DOJ Announces More Lenient Corporate Cooperation Policy

In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more

Troutman Pepper Locke

Revised DOJ Corporate Cooperation Policy Supports More Efficient Resolutions

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On November 29, Deputy Attorney General Rod Rosenstein announced revisions to the Department of Justice’s policy on corporate cooperation in government investigations, which may make it easier for companies under...more

The Volkov Law Group

OFAC Enforcement: The Epsilon Case and Third Party Risks

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The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. This case requires a theme song and there is none better than Trucking from Grateful...more

Hogan Lovells

Japan's plea bargaining system

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A new plea bargaining system – offering reduced penalties to companies that report certain violations and cooperate with government investigations – will come into effect in Japan this June, reflecting an amendment to the...more

Thomas Fox - Compliance Evangelist

Responding to Investigative Findings

Most companies understand a the need for an investigative protocol or bringing in experienced investigative counsel should a substantive Foreign Corrupt Practices Act (FCPA) allegation arise. However what is not as well known...more

The Volkov Law Group

DOJ Continues Run on Individual FCPA Criminal Prosecutions

The Volkov Law Group on

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more

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