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National Security › FCPA Corporate Enforcement Policy (CEP)

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

Woods Rogers on

On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

The Volkov Law Group

Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls...

The Volkov Law Group on

A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a number of significant indicators of a...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Its Approach to Encourage Voluntary Self-Disclosures of Export Control and Sanctions Violations

Orrick, Herrington & Sutcliffe LLP on

On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more

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