Yates Memo: More Change Coming in FCPA Enforcement
Two weeks ago, Foreign Corrupt Practices Act enforcement took a formal turn when the Justice Department released the Yates Memo, which formalized the department’s new focus on prosecuting individuals under the FCPA. In the same week, there was a much less reported event that could have equally large effect on ...
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Employee Investigations Post-Yates Memo
Image: Any company that has faced allegations of corporate misconduct knows how quickly the scope and cost of an internal investigation can grow—a concern that has only amplified following the Justice Department’s Yates Memo. “Corporate compliance professionals have expressed concern that this policy will result in companies undertaking unnecessarily broad, ...
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ArticleSFO sharpens framework for judging compliance programs in bribery and fraud cases
The U.K. Serious Fraud Office (SFO) has updated its guidance about how it evaluates corporate compliance programs when considering whether to prosecute or offer leniency to companies that have breached bribery and corruption laws.
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PremiumThe FCPA’s origin story: Why “Bribery Beyond Borders” is essential reading
I have often thought the facts of many Foreign Corrupt Practices Act (FCPA) enforcement actions would make the basis for a great series of crime-thriller books. But it turns out the origins of the FCPA itself are as dynamic, fast-paced and exciting as any such work of fiction.