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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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Potpourri
A bounty and a disclosure. Bounty Earlier this week the SEC released this order determining that a whistleblower is to receive approximately $3.5 million. According to the order: “Claimant alerted...
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Japanese Ministry of Economy, Trade and Industry Updates Guidance to Prevent...
A guest post from Tokyo-based Latham & Watkins attorneys Kaede Toh and Junyeon Park. In May 2021, the Ministry of Economy, Trade and Industry (METI) revised the Guidelines for the Prevention of...
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Amec Foster Wheeler / John Wood Group Enforcement Actions – What Actually Was...
Previous posts here, here, here and here highlighted various aspects of the recent U.S. and U.K. enforcement actions against Amec Foster Wheeler / John Wood Group. The enforcement actions included: (i)...
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Amec Foster Wheeler / Wood Group – In The Words Of Lord Justice Edis
If a country is to have a deferred prosecution agreement regime, the approach of the United Kingdom is far more preferable than the approach of the United States. In the U.K. (unlike the U.S.), the...
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Using An Asset Purchase Transaction Structure To Mitigate FCPA Risk
This post is authored by Foley & Lardner attorneys David Simon, Rohan Virginkar, James Peterson, Kristen Maryn and Stephanie Cash. Experienced practitioners and dealmakers understand there may be...
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Issues To Consider From The Cardinal Health Enforcement Action
This recent post highlighted the SEC’s $8.8 million Foreign Corrupt Practices Act enforcement action against Cardinal Health. This post continues the analysis by highlighting additional issues to...
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Cardinal Health Resolves $8.8 Million Enforcement Action Based On A Former...
Last Friday the SEC announced that Cardinal Health Inc. agreed to pay $8.8 million to resolve a Foreign Corrupt Practices Act enforcement action. The action is based on a Cardinal entity (acquired in...
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