CMM | Campolo, Middleton, McCormick, LLP

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

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

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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Supreme Court Holds That Disgorgement Is a Penalty Subject to the Statute of Limitations

Posted: June 26th, 2017

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Disgorgement is a legal remedy requiring defendants to pay back unlawful gains, which the SEC often seeks in addition to […]

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Volkswagen Guilty Plea Sets New Standards for White Collar Investigations and Enforcement

Posted: January 27th, 2017

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On Wednesday, January 11, 2017 German auto-maker Volkswagen pleaded guilty to charges of conspiracy to commit wire fraud and to […]

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

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

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

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 settle SEC […]

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

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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Lessons Learned From The Novartis FCPA Settlement

Posted: July 25th, 2016

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Last spring, Swiss pharmaceutical giant Novartis AG paid $25 million to the SEC to settle Foreign Corrupt Practices Act (“FCPA”) […]

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New Treasury Efforts to Fight Money Laundering Through New York Real Estate

Posted: January 25th, 2016

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To combat the scourge of money laundering from transnational criminal syndicates, the United States Treasury has issued new Geographic Targeting […]

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The SEC Reminds Us: An Ounce of Prevention is Worth a Pound of Cure

Posted: November 20th, 2015

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On November 4, 2015, Andrew Ceresney, the head of the Security and Exchange Commission’s (“SEC”) enforcement division, delivered the keynote […]

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Pay Your Attorney Now: Supreme Court Considers Legality of Seizing Untainted Money

Posted: November 20th, 2015

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The headline is not just shameless attorney self-promotion, but in fact reflects sound advice to anyone or any company facing […]

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Second Circuit Upholds Use of Undisclosed Third Party Software to Provide Probable Cause in Search Warrant

Posted: July 15th, 2015

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While the crimes themselves are despicable, child pornography prosecutions often feature cutting-edge forensic investigation techniques and challenges that are applicable […]

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