Entries tagged: fcpa

In a Blow to Government, Second Circuit Curtails Extraterritorial Reach of FCPA

Posted: October 18th, 2018

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In a recent decision with implications for the extraterritorial reach of the Foreign Corrupt Practices Act (FCPA), the U.S. Court […]

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Société Générale Settles One of the Largest Anti-Corruption Enforcement Actions in History

By: Jack Harrington, Esq.

Posted: June 13th, 2018

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On June 4, 2018, Paris-based financial giant Société Générale agreed to pay the United States and France a total of […]

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To Disclose or Not to Disclose: The DOJ’s New Anti-Corruption Corporate Enforcement Policy

By: Jack Harrington, Esq.

Posted: April 20th, 2018

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In April 2016, the Department of Justice (DOJ) launched an experimental Foreign Corrupt Practices Act (FCPA) enforcement policy known as […]

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Lessons Learned from FCPA Enforcement in 2017

By: Jack Harrington, Esq.

Posted: January 22nd, 2018

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The Department of Justice’s (“DOJ”) Foreign Corrupt Practices Act (“FCPA”) enforcement efforts ended 2017 with a bang on December 22, […]

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Thinking Positively About International Compliance

By: Jack Harrington, Esq.

Posted: July 28th, 2017

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Companies tend to think about corporate functions as one of two things: a revenue center or a cost center.  An […]

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JP Morgan Pays $264 Million to Resolve “Princelings” FCPA Investigation

By: Jack Harrington, Esq.

Posted: December 20th, 2016

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Last month, JP Morgan entered into a landmark settlement agreement in which it agreed to pay $264.4 million to the […]

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The Internationalization of Anti-Corruption Investigations and Enforcement

By: Jack Harrington, Esq.

Posted: November 28th, 2016

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In November 2016, France adopted new anti-corruption legislation permitting deferred prosecution agreements in bribery cases.  In July 2017, Mexico’s new […]

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When a Charitable Donation is a Bribe

By: Jack Harrington, Esq.

Posted: October 26th, 2016

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    On September 20, 2016, Nu Skin Enterprises, Inc., a Utah-based skincare products manufacturer, agreed to pay $765,688 to […]

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How to Avoid a “Paper” Anti-Corruption Compliance Program

By: Jack Harrington, Esq.

Posted: September 16th, 2016

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    In December 2008, Siemens AG, Europe’s largest engineering and electronics conglomerate, settled Foreign Corrupt Practices Act (“FCPA”) charges […]

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Life Science Companies under Increasing DOJ and SEC Scrutiny for Anti-Corruption Enforcement

By: Jack Harrington, Esq.

Posted: August 23rd, 2016

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The pharmaceutical and medical device industry has always been among the most heavily regulated in the United States.  In recent […]

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