The Yates Memo and the new normal for individual enforcement
In a speech before the New York bar, Justice Department Deputy Assistant Sally Yates detailed some of the effects the Justice Department has already seen from the Yates Memo, released last September, including a larger focus on individual actor culpability and a drive by DoJ lawyers to identify the individuals ...
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Navigating the risks of individual accountability for corporate wrongdoing
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PremiumPart Two: FCPA cases closed by DOJ, SEC since January
Since the start of the Trump Administration, the Department of Justice has been winding down a number of Foreign Corrupt Practices Act investigations with little public attention. This second article further explores how and why these FCPA matters have been closed.
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News BriefDOJ secures $118 million penalty in FCPA violation case tied to Guatemalan telecom firm
The parent company of a telecom subsidiary in Guatemala agreed to pay $118.2 million to settle allegations of improper payments made to government officials, but the U.S. Department of Justice chose not to impose a compliance monitor to administer the firm’s compliance with the Foriegn Corrupt Practices Act (FCPA).