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Declination Bribery Disgorgement

The Volkov Law Group

Episode 383 -- FCPA Update: Declination and Indictment

The Volkov Law Group on

Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed -...more

Bradley Arant Boult Cummings LLP

DOJ Expands Availability of Declinations with Disgorgement for Corporations that Self-Disclose Misconduct

Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges...more

The Volkov Law Group

Catching Up with FCPA News

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DOJ closed out its FCPA enforcement year in 2022 with two significant settlements, the ABB and Honeywell cases.  Aside from these two big settlements, there was a flurry of other actions in the last quarter of 2022....more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2022

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

The Volkov Law Group

DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy

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In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more

Thomas Fox - Compliance Evangelist

The FCPA Corporate Enforcement Policy in Action-Part I

We had three major Foreign Corrupt Practices Act (FCPA) cases resolved in Q2 2018. They all reached different resolutions under the new FCPA Corporate Enforcement Policy and the new anti-piling on policy....more

Dorsey & Whitney LLP

Anti-Corruption Digest - July 2017

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Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more

The Volkov Law Group

Justice Department Resolves Two Cases Under FCPA Pilot Program

The Volkov Law Group on

The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more

Holland & Knight LLP

Gas Company Receives First Declination of 2017 Under FCPA Pilot Program

Holland & Knight LLP on

The U.S. Department of Justice (DOJ) on June 16, 2017, announced its first declination of 2017 and the closing of its investigation of Linde North America Inc. and Linde Gas North America LLC (collectively, Linde) concerning...more

Thomas Fox - Compliance Evangelist

Declinations and Profits Disgorgement – It Was There All Along

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

Thomas Fox - Compliance Evangelist

Enforcement Week III: Johnson Controls FCPA Enforcement Action – Part 2

I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the...more

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