In February, the Department of Justice unsealed an indictment against two former executives of the Indonesian subsidiary of Alstom S.A., Reza Moenaf and Eko Sulianto, and a former executive of Marubeni Corporation, Junji Kusunoki.… Continue Reading
All posts by Jesse Van Genugten
A trove of money laundering scandals erupted in Northern Europe this year, tying major financial institutions from all three Scandinavian countries to alleged bribery schemes, attempts to evade U.S. sanctions, and serious regulatory failures.… Continue Reading
The Department of Justice recently updated and published its guidelines for evaluating corporate compliance programs in the FCPA context. The Guidelines are remarkably thorough, but the text is aimed principally at assisting prosecutors with charging decisions, setting sanction amounts, and crafting subsequent compliance obligations — rather than at the corporate entities that are expected to phase in those compliance programs.… Continue Reading
The Netherlands, a country well respected in many regards for its commitment to organized labor and workers’ rights, fails even to marginally protect a different class of vulnerable employee: the whistleblower.… Continue Reading
In a novel, even if rather obscure manner, the Trump Administration has found a new way to put America first.