Entries tagged: fcpa

image-

The Second Circuit Declines to Extend the U.S. Supreme Court’s McDonnell “Official Act” Reasoning to the Foreign Corrupt Practices Act

By: Jack Harrington, Esq. email

Posted: August 23rd, 2019

Tags: ,

In 2016, in McDonnell v. United States, the U.S. Supreme vacated the former Virginia Governor’s bribery conviction by limiting the […]

Read More email

image-

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

By: Jack Harrington, Esq. email

Posted: October 18th, 2018

Tags:

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

Read More email

image-

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

By: Jack Harrington, Esq. email

Posted: June 13th, 2018

Tags:

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

Read More email

image-

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

By: Jack Harrington, Esq. email

Posted: April 20th, 2018

Tags: , , ,

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

Read More email

image-

Lessons Learned from FCPA Enforcement in 2017

By: Jack Harrington, Esq. email

Posted: January 22nd, 2018

Tags: ,

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

Read More email

image-

Thinking Positively About International Compliance

By: Jack Harrington, Esq. email

Posted: July 28th, 2017

Tags: ,

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

Read More email

image-

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

By: Jack Harrington, Esq. email

Posted: December 20th, 2016

Tags: , ,

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

Read More email

image-

The Internationalization of Anti-Corruption Investigations and Enforcement

By: Jack Harrington, Esq. email

Posted: November 28th, 2016

Tags: , ,

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

Read More email

image-

When a Charitable Donation is a Bribe

By: Jack Harrington, Esq. email

Posted: October 26th, 2016

Tags: , ,

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

Read More email

image-

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

By: Jack Harrington, Esq. email

Posted: September 16th, 2016

Tags: ,

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

Read More email