Global Investigations Review - The law and practice of international investigations

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Daniel Kahn: Not self-disclosing could count against compliance programme

The decision to self-disclose could have implications beyond the amount a company can receive off a criminal penalty, the acting head of the foreign bribery unit said on 2 May.

World Bank immune from discovery requests, Canada’s Supreme Court rules

World Bank immune from discovery requests, Canada’s Supreme Court rules

Canada’s highest court has ruled that the World Bank does not have to turn over documents from a corruption investigation into construction company SNC-Lavalin to defendants fighting related foreign bribery charges.

Wells Fargo anti-bribery chief: pilot programme means 120 per cent cooperation required

Wells Fargo anti-bribery chief: pilot programme means 120 per cent cooperation required

Wells Fargo’s anti-bribery chief, who recently called on the DOJ to offer clearer guidance on how it evaluates corporate compliance programmes, has said businesses will need to ratchet up their internal controls as a result of the FCPA pilot programme.

Houston oilfield services company receives DOJ declination

Houston oilfield services company receives DOJ declination

The Justice Department has notified Key Energy Services, a Houston-based oilfield services company, that it will not prosecute the company over allegations of foreign bribery.

FCPA Docket: Law firm commercial reveals client’s foreign bribery subpoena

29 April 2016 - US and Uzbek authorities negotiate over which country has the rights to assets tied to the VimpelCom bribery scandal, and a corporate executive reveals the cost of an FCPA subpoena by the US government – in a law firm commercial.

Leslie Caldwell: 'deconfliction' requests should be rare

The Justice Department should rarely request companies to hold off on interviewing employees in internal investigations, Assistant Attorney General Leslie Caldwell has said.

DOJ prosecutor addresses FCPA pilot programme disgorgement question

Deputy Assistant Attorney General Sung-Hee Suh has shed light on how the Justice Department will require companies that secure declinations to disgorge ill-gotten profits in foreign bribery cases.

Meet the NYU scholar whose work foreshadowed the DOJ’s new approach to corporate enforcement

Just Anti-Corruption interviews Jennifer Arlen, the long-time NYU Law School professor who some have credited as influencing recent DOJ policy on white-collar and corporate enforcement.

White & Case nabs fifth white-collar partner from McDermott

Matthew Turnell has become the fifth partner to leave McDermott Will & Emery for White & Case’s white-collar practice in less than a month.

Lawyers divided on how the DOJ’s new disgorgement requirement will work

The Justice Department has left unanswered questions about how it will require companies seeking declinations to disgorge ill-gotten gains, as part of its new policy outlined in the Foreign Corrupt Practices Act pilot programme.

Editor's picks

The “gold standard” bill that would protect internal whistleblowers

The “gold standard” bill that would protect internal whistleblowers

US courts disagree whether Dodd-Frank protects individuals from retaliation if they only report misconduct to their employer. But in Congress, there are moves afoot to end the uncertainty and provide internal whistleblowers with unambiguous protection.

DOJ clears ambiguity in FCPA pilot programme

DOJ clears ambiguity in FCPA pilot programme

The Justice Department has clarified what it means when it says companies must deconflict their internal investigations from the government’s parallel probe to receive full cooperation credit, following a request from Just Anti-Corruption.

  • Sally Yates rejected bolder approach to declinations

    Sally Yates rejected bolder approach to declinations

    The criminal division’s new FCPA pilot programme is a scaled back version of a more ambitious proposal that was rejected last year by Deputy Attorney General Sally Yates, according to people with knowledge of the matter.

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