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Entries in Cooperation (33)

Monday
Dec192016

Rebecca Gantt: Looking for clues about the future of the Pilot Program

Last April, the DOJ's Criminal Division launched the one-year Pilot Program. The remaining four months of the Pilot Program promise to provide valuable information on several fronts.

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Friday
Oct282016

Lanny Breuer: Pilot Program falls short

The DOJ's Pilot Program to encourage companies to self report bribery and cooperate with prosecutors doesn't fix some problems with FCPA investigations and enforcement actions, Lanny Breuer said Wednesday.

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Wednesday
Oct122016

Matt Reeder: Do Pilot Program disclosures raise risks of carbon copy prosecutions?

In April the DOJ launched its FCPA self-reporting Pilot Program for the purpose of increasing the number of companies voluntarily disclosing FCPA violations. The program was designed to achieve this goal with a carrot and stick approach.

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Tuesday
Sep132016

Jorge and Kenney: Argentina considers bill to enable corporate bribery prosecutions

Argentina's National Congress will soon consider a bill that would finally enable prosecutors to bring criminal charges against corporations that engage in bribery and other corrupt acts.

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Monday
Aug152016

What's behind Key Energy's ‘disgorgement-only’ settlement?

Key Energy Services, Inc. resolved an SEC enforcement action Friday by disgorging $5 million but not paying any other penalties.

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Tuesday
Jul122016

Johnson Controls pays SEC $14 million to settle China bribe case, receives DOJ Pilot Program declination

Johnson Controls Inc. agreed Monday to pay $14 million to settle SEC charges that it violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act.

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Thursday
Jun232016

The Analogic Settlement: What's behind the issue of cooperation credit?

As reported by the FCPA Blog Tuesday, the SEC and DOJ entered into parallel resolutions with Analogic Corporation and Analogic's wholly-owned Danish subsidiary BK Medical ApS in connection with violations of the books and records and accounting controls provisions of the FCPA.

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Wednesday
Jun082016

Here's what a Pilot Program declination letter looks like

After Nortek and Akamai resolved FCPA enforcement actions with the SEC Tuesday with non-prosecution agreements requiring cooperation and disgorgement, both companies released declination letters issued under the DOJ's new Pilot Program.

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Wednesday
May112016

Yates Speaks: Prosecuting individuals is really hard, so companies need to come clean

Deputy Attorney General Sally Q. Yates spoke Tuesday to the New York City Bar Association White Collar Crime Conference. Her topic? That's right. The Yates Memo, more formally known as the DOJ's Individual Accountability Policy.

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Thursday
Mar312016

SFO: How should companies handle attorney-client privilege during investigations?

Alun Milford, SFO General Counsel (image courtesy fo the SFO)In a speech this week to compliance professionals at the European Compliance and Ethics Institute in Prague, the general counsel of the UK Serious Fraud Office talked about attorney-client privilege in connection with SFO corruption investigations.

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Thursday
Mar172016

Joseph Spinelli on the Yates Memo: Expect DOJ investigations to become very personal

Last week Kroll and the Ethisphere Institute released their 2016 Anti-Bribery and Corruption Benchmarking Report: The Year of Global Expansion and Enforcement.

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Friday
Feb262016

Tom Fox on VW: The cost of a ‘strategy of delay and obfuscation’

Still wondering what the cost of a culture of non-compliance might be? Earlier this month Volkswagen announced it would delay reporting its annual earnings and move back the date of its annual shareholders’ meeting because of uncertainty about the cost of its diesel emissions scandal.

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