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Entries in Cooperation (48)


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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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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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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SFO to companies with compliance problems: This is how you deal with us

Ben Morgan, the joint head of the bribery and corruption unit at the UK Serious Fraud Office, spoke Thursday morning to the Annual Anti Bribery and Corruption Forum in London.

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PetroTiger joins Morgan Stanley with rare DOJ public declination

For only the second time in FCPA history, the DOJ Monday made a public announcement that it wouldn't prosecute a company that cooperated in building a case against a former officer.

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SFO: DPAs are a chance to live your corporate values

Ben Morgan, joint head of bribery and corruption at the UK Serious Fraud Office, spoke at this year's Global Anti-Corruption and Compliance in Mining Conference in London. He talked about the benefits of cooperation (sound familiar?).

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Cooperation: SEC enforcement boss talks about benefits to individuals

SEC enforcement chief Andrew CeresneyDuring a speech Wednesday at the University of Texas law school in Dallas, Andrew Ceresney, chief of the SEC's enforcement division, talked about the three main benefits of cooperation for individuals.

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Getting real: FCPA investigations shouldn't ‘boil the ocean’

Companies that might become embroiled in seemingly perpetual DOJ FCPA investigations recently received some mixed messages from DOJ’s Criminal Division. On April 17, Leslie Caldwell, the AAG of the Criminal Division, delivered remarks at New York University Law School’s Program on Corporate Compliance and Enforcement.

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BNP trampled compliance officers, pays record $9 billion penalties for sanction offenses

Paris-based BNP Paribas S.A. was sentenced Friday for processing billions of dollars of transactions through the U.S. financial system on behalf of Sudanese, Iranian and Cuban entities subject to U.S. economic sanctions. 

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Reader: When dealing with the DOJ, groveling helps

Dear FCPA Blog,

Thanks for the post about cooperation with the DOJ, which quoted from a recent talk by the DOJ's Leslie Caldwell. Unfortunately, my real world experience in FCPA investigations and cooperation has looked slightly different.

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Resource alert: This is what cooperation with the DOJ looks like

When companies have FCPA problems, their decision to cooperate with the DOJ can save them tens of millions of dollars. What is cooperation?

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Pleasure or pain? Voluntary FCPA disclosure and cooperation

In our recent report, Trends and Developments in Anti-Corruption Enforcement, we analyze major anti-corruption resolutions in 2014 and look ahead to what we expect in 2015.

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