Clik here to view.
Bad Advertising – Ad Group WPP Resolves $19.2 Million FCPA Enforcement Action
Last Friday, the SEC announced that London-based WPP (the world’s largest advertising agency and a company with depositary shares traded on the New York Stock Exchange) agreed to resolve a $19.2...
View ArticleClik here to view.
Stericyle Resolves A Net $59 Million FCPA Enforcement Action
Stericycle (an Illinois based medical waste disposal company) has been under FCPA scrutiny since mid-2017 (See here). As highlighted here, approximately two months ago the company disclosed that it had...
View ArticleClik here to view.
Assistant AG Kenneth Polite On Deterrence And Compliance Certifications
It is mid-September. Thus, consistent with historical practices, DOJ officials are out giving speeches about DOJ policy. Previous posts here and here have focused on the recent release of the so-called...
View ArticleClik here to view.
Principal Associate Deputy Attorney General Miller On Voluntary Disclosure,...
It is September which means enforcement agency officials hit the “conference circuit” to give scripted speeches. Today it was Principal Associate Deputy Attorney General Marshall Miller speaking at a...
View ArticleClik here to view.
DOJ Announces A “New Safe Harbor Policy For Voluntary Disclosures Made In...
For years, DOJ officials have been talking about policy issues surrounding merger & acquisition activity and potential criminal conduct. Earlier this week, Deputy Attorney General Lisa Monaco...
View ArticleClik here to view.
What Others Are Saying About The DOJ’s “Safe Harbor” M&A Policy
This prior post highlighted the DOJ’s “New Safe Harbor Policy For Voluntary Disclosures Made In Connection With Mergers and Acquisitions.” As discussed in the post, substantively the policy is not...
View ArticleClik here to view.
Acting Assistant Attorney General Argentieri On …
Another day, another speech by a DOJ official. Recently, Acting Assistant Attorney General Nicole Argentieri delivered this speech in which she discussed the following topics: foreign law enforcement...
View ArticleClik here to view.
Principal Associate Deputy AG Marshall Miller On …
Recently, Principal Associate Deputy Attorney General Marshall Miller delivered this speech. He focused his remarks on “how today’s world demands that the Department of Justice expand, innovate, and...
View ArticleClik here to view.
Issues To Consider From The Deere & Co. Enforcement Action
This previous post highlighted the $9.9 million Foreign Corrupt Practices Act enforcement actions against Deere & Co. concerning subsidiary conduct in Thailand. This post highlights additional...
View ArticleClik here to view.
An Interesting Disclosure
In late 2014, Alstom and related entities resolved a $772 million DOJ FCPA enforcement action. The enforcement action concerned conduct in several countries including Saudi Arabia in which the DOJ...
View Article