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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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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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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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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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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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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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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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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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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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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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