The DOJ and SEC published the Second Edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act Friday, updating for the first time the best government-produced FCPA guidance.… Continue Reading
Posts Tagged: Piling on
The UK Serious Fraud Office filed charges Friday against a third former executive of Güralp Systems Limited.
Heather Pearce, the former sales director, was charged with conspiracy to bribe a foreign official.… Continue Reading
The prosecutor who oversees the criminal division’s FCPA unit said the DOJ wants corporate acquisitions to happen and doesn’t want the “specter of enforcement to be a risk factor that impedes such activity by good actors.”… Continue Reading
In a series of key policy announcements between November 2017 and May 2018, the Department of Justice has demonstrated an increasingly coherent perspective on how it will handle key aspects of white collar criminal enforcement.… Continue Reading
On May 9 the DOJ announced a new policy concerning the coordination of penalties imposed by more than one regulator or law enforcement authority in corporate resolutions.
This new policy (pdf) against “piling on” requires DOJ attorneys to “coordinate with one another to avoid the unnecessary imposition of duplicative fines, penalties, and/or forfeiture against [a] company,” and further instructs DOJ personnel to “endeavor, as appropriate, to .… Continue Reading
A common refrain in the white collar bar is that American government agencies don’t often get along and play well together. This can result in challenging issues for companies doing business in the United States that have run afoul of the law.… Continue Reading
Deputy Attorney General Rod Rosenstein announced a new policy Wednesday that encourages coordination among DOJ departments and other enforcement agencies to avoid multiple penalties for the same conduct.
The aim is to avoid unfair duplicative penalties while keeping good relationships with law enforcement partners in the United States and abroad, Rosenstein said.… Continue Reading