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Entries in Yates Memo (31)


NGOs to OECD: Corporate pretrial agreements can work, but we still need deterrence

The OECD is hosting an Anti-Bribery Ministerial meeting Wednesday (March 16) to discuss how to strengthen implementation of its Anti-Bribery Convention. One of the issues on the table for discussion is how to encourage voluntary disclosure by companies of wrongdoing and how settlements can be used to do that.

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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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Bill Steinman: Reports of the FCPA’s demise are greatly exaggerated (and just plain wrong)

This time of year, FCPA prognosticators abound.  Just as the arrival of a New Year is heralded by the popping of champagne corks, January brings with it much gazing into our FCPA crystal balls. Looking back over the prior year, we do our best to offer insight into what enforcement trends the New Year will bring.

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Paul Pelletier: Will the Yates Memo further delay corporate FCPA resolutions?

While the much heralded Yates Memo has produced a frenzy of “what does it mean?” reporting, few analysts have examined the depth and breadth of the issues and events that led DOJ to re-emphasize the focus on prosecution of corporate executives.

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Tom Fox on VW and the Yates Memo

Coming on the heels of the GM settlement for defective ignition switches where there were no prosecutions of individuals, the VW scandal will be a test for the Department of Justice and its new policy announced a few days ago with the Yates Memo.

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Are settlements a deterrent or a dodge?

The DOJ has unveiled new guidance to federal prosecutors about bringing criminal cases against individuals in instances of corporate wrongdoing.

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Richard Bistrong: Turn off the movie and read the Yates Memo

When I was asked last week during a TV interview if I once believed I could do wrong with impunity, I responded, “I never thought about getting caught.” Now, almost ten years after my last criminal act, comes the Yates Memo.

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