In September 2015, Sally Yates, then Assistant Attorney General, announced the Memo that bears her name (Yates Memo), saying, “we have revised our policy guidance
Now that you have set your Board of Directors, investigations protocol, we consider some of the key factors which will lead to the successful conclusion
Many companies have an investigation protocol in place when a potential compliance violation or other legal issue arises. However, many Boards of Directors do not
You may find yourself in the position that you will have to have some very frank discussions about what to expect in terms of costs
Who to suspend during any FCPA investigation is always a delicate question to answer and is never easy to answer. As the VW emission-testing scandal reverberated,
Beginning with the 2015 Yates Memo, 2016 FCPA Pilot Program, 2017 and 2019 Evaluations of Corporate Compliance Programs, with 2020 Update through to the FCPA
Under Part 1, Section D. Confidential Reporting Structure and Investigation Process, it stated in part, Properly Scoped Investigation by Qualified Personnel –What steps does the
Is your hotline working for you? In an article, entitled “Promoting Effective Use of the Company Compliance Hotline”, José Tabuena provided an excellent example of the
The FCPA states, “The FCPA’s anti-bribery provisions apply to corrupt payments made to (1) “any foreign official”; (2) “any foreign political party or official thereof”;
Opinion Releases can provide valuable information for the compliance practitioner. I agree with the statement found in the 2012 FCPA Guidance that “DOJ’s opinion procedure is
