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The Man From U.N.C.L.E. and Modern FCPA Enforcement

Tom Fox | August 17, 2015

I recently saw the movie The Man From U.N.C.L.E. It was a rollicking good movie, stylish, set in great locations, with a fabulous score and all the Guy Ritchie touches you would expect. The action all took place in Europe and the locals and governmental cooperation among the U.S., U.K. and Soviet governments seemed to foretell one of the current international focuses: the fight against bribery and corruption.

The Wall Street Journal reported last week that the U.S. Justice Department “filed a complaint in June with a New York court as a step toward asking Irish, Belgian and Luxembourg authorities to restrain about $300 million held in bank accounts in those countries.” Later in July, U.S. District Judge Andrew Carter allowed the Justice Department to impound the funds held by Bank of New York Mellon Corp. in Ireland,...

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