Breuer – Siemens Investigation (As to Individuals) Remains Open
Last week, Lanny Breuer (Assistant Attorney General – Criminal Division) testified before The Criminal Law Subcommittee of the Senate Judiciary Committee. During his Q&A exchange with Senator Arlen...
View ArticleThe FCPA and Reputational Damage
Nearly every FCPA presentation one sees or hears seems to talk about collateral sanctions which flow from an FCPA enforcement action, including the reputational harm companies “suffer” when disclosing...
View ArticleCongressman Towns Is Asking The Right Questions
One interesting, surprising, and controversial aspect of FCPA enforcement is that the U.S. government remains a lucrative customer for many FCPA violators, including some of the most egregious...
View ArticleThe Holder Memo and FCPA Enforcement
Attorney General Eric Holder recently issued a memo (here) regarding “Department Policy on Charging and Sentencing.” There is little that is new is this memo; in fact Holder states that the purpose of...
View ArticleWhen the Dust Settles
Documents used to resolve a typical FCPA enforcement action (whether a non-prosecution or deferred prosecution agreement, plea, or settled civil complaint) are often peppered with vague generalities....
View ArticleTurkey and the FCPA
The following FCPA enforcement actions have involved (in whole or in part) business conduct in Turkey. Daimler AG (March 2010) In March 2010, Damiler AG agreed to settle a wide-ranging FCPA enforcement...
View ArticleWill There Be Any Daimler-Related Prosecutions?
Bribery schemes are often facilitated, aided and abetted, and enabled by third parties and with increasing frequency the DOJ targets such enablers. In November 2009, Assistant Attorney General Lanny...
View ArticleThe Siemens Argentina Individual Enforcement Actions Are A Step Forward, But...
Last week (see here for the prior post) the DOJ and SEC brought FCPA enforcement actions against several former executives and agents of Siemens. As noted in this initial post, the enforcement action...
View ArticleFriday Roundup
A costly monitor, Daimler’s DPA debacle, meeting releases, and another addition to the list (in an unusual way), it’s all here in the Friday roundup. Willbros Monitor Costs Earlier this week, Willbros...
View ArticleFriday Roundup
Shining a light on monitor reports, the Wal-Mart effect, when the dust settles, and Alberto Gonzalez joins the club, it’s all here in the Friday roundup. Shining A Light on Monitor Reports As Willkie...
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