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Troutman Pepper Locke

DOJ’s Revised Self-Disclosure Policy May Offer Companies More Certainty

Troutman Pepper Locke on

Last month, the DOJ Criminal Division (Division) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), introducing several potentially significant changes intended to further incentivize companies to...more

Hogan Lovells

Stericycle DPA signals more aggressive use of independent compliance monitors

Hogan Lovells on

On April 20, 2022, the U.S. Department of Justice (DOJ) announced it had entered a three-year deferred prosecution agreement (DPA) with Stericycle Inc. to resolve allegations that it violated the Foreign Corrupt Practices Act...more

A&O Shearman

Technology Company Resolves DOJ And SEC FCPA Allegations, With Hungary Subsidiary Entering Three-Year, Monitor-Free NPA

A&O Shearman on

On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 5: Ringo and The End – Microsoft FCPA Settlement – Part 4

Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more

Thomas Fox - Compliance Evangelist

Drum Solo Week 4: In-A-Gadda-Da-Vida – Microsoft FCPA Settlement – Part 3

Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more

The Volkov Law Group

Microsoft Pays DOJ and SEC $25 Million to Resolve FCPA Violations (Part I of III)

The Volkov Law Group on

Microsoft finally resolved its FCPA enforcement action with a whimper.  Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more

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