Recently Gurbir Grewal (the SEC’s Director of the Division of Enforcement) delivered this speech titled “The Five Principles of Effective Cooperation in SEC Investigations” at a securities law conference.
This post summarizes the speech and provides factual information and rebuttal points relevant
This post highlights developments in the United Kingdom regarding foreign bribery enforcement actions.
As highlighted here, a director of PV Energy Ltd (Peter Virdee also known as Hardip Singh) was charged with bribing a foreign public official in that
As highlighted in this prior post, in September 2015 then DOJ Deputy Attorney General Sally Yates delivered this speech and released this memo titled “Individual Accountability for Corporate Wrongdoing. (See here for the video of the speech). Like certain other
One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted.
For instance, the FCPA enforcement agencies often talk about the importance of x and how they are committed to x, but in
It happens rather frequently in professional circles.
A term is used and it sounds fancy and sophisticated. The term is repeated again and again as if everyone knows what it means.
But the reality. often. is the term is vague
Testing innocence in a criminal matter can impose substantial burdens on a defendant.
Particularly when that defendant is a foreign national in the United States separated from his family.
As highlighted in this prior post, in September 2019 the
In 2016, Qualcomm resolved a Foreign Corrupt Practices Act enforcement action (see here) based on alleged improper hiring and other practices in China.
In resolving the matter, Qualcomm agreed to cease and desist from committing or causing any future FCPA
The Foreign Corrupt Practices Act enforcement agencies bring enforcement actions against companies in which the allegations often include lack of due diligence or risk management in connection with certain transactions.
As explained on its website, the Export-Import Bank of
Today’s post is from Sara Kropf. A shorter version of this post was published by Bloomberg News on May 14, 2024. (See here).
I’ve written before about the Department of Justice’s questionable tactics in an FCPA case against two former executives for