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We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017. From the narrow perspective of FCPA enforcement, the Justice Department and the SEC have demonstrated
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Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination. You can listen to our podcast here. It is always a pleasure to
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The Justice Department finally released its long-awaited new FCPA enforcement plan. It took DOJ a little while to come up with this and in the end, like most initiatives, there is a mixed bag for global companies, FCPA practitioners, DOJ prosecutors and law enforcement. Today’s posting analyzes the