Our team has unsurpassed experience in counseling and defending U.S. and foreign companies and individuals in matters relating to the U.S. Foreign Corrupt Practices Act and similar anti-corruption laws. We are frequently contacted when a potential corruption issue arises, and are go-to counsel for investigations and enforcement proceedings before the U.S. Department of Justice (DOJ), the Securities & Exchange Commission (SEC) and the Multilateral Development Banks, including the World Bank. In addition, we advise clients considering transactions in high-risk markets or with business partners with high anti-corruption risks. We also counsel clients who are designing compliance programs and in conducting risk assessments.

FCPA Enforcement and Anti-Corruption Developments: Q1 2018

The first quarter of 2018 saw a flurry of declinations of FCPA prosecutions by the DOJ and the SEC, and only one FCPA corporate enforcement resolution by the DOJ and two resolutions by the SEC. 

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DOJ Issues New Policy on Coordination of Corporate Penalties to Address “Piling On”

Yesterday, Rod Rosenstein, Deputy Attorney General of the U.S. Department of Justice, announced a new policy, in the form of an addition to the United States Attorneys’ Manual (“USAM”), concerning the coordination of corporate resolution penalties in cases involving penalties imposed by more than one regulator or law enforcement authority.

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Alex Oh Publishes Article on Corporate Compliance and HR in The Anti-Corruption Report

Litigation partner Alex Oh's article, “The ‘Human’ Side of FCPA Compliance: How to Best Work With HR in the Current Global Enforcement Environment” appeared in the March 7 issue of The Anti-Corruption Report. 

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How Regulators Are Assessing Corporate Compliance Programs

What makes an effective corporate compliance program? And how do regulators evaluate them? The U.S. Department of Justice recently issued guidance on evaluating the effectiveness of corporate compliance programs in criminal investigations.

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FCPA Enforcement and Anti-Corruption Developments: 2017 Year In Review

Despite significant FCPA enforcement activity in 2017, the Trump administration’s approach to enforcement remains elusive and not readily characterized.  While actions against individuals were at the highest level in recent years, corporate resolutions declined from last year’s record-breaking numbers, falling back within the range of such numbers over the last several years.

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JPMorgan Settles Referral Hiring Investigations

Paul, Weiss represented JPMorgan in connection with its recent resolutions with the U.S. Department of Justice, the Securities and Exchange Commission and the Federal Reserve relating to investigations of JPMorgan's hiring candidates referred by clients, potential clients and government officials in the Asia-Pacific region.

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FCPA Pilot Program: One-Year Retrospective

The U.S. Department of Justice recently announced that it is extending its FCPA Pilot Program, which was launched in April 2016, while they evaluate the program.

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Paul, Weiss Adds Experienced Compliance Counsel to FCPA Practice

Paul, Weiss, Rifkind, Wharton & Garrison LLP announced today that Peter Jaffe has joined the firm as counsel in its Washington, D.C. office, expanding the firm's deep bench of skilled United States Foreign Corrupt Practices Act (FCPA) practitioners and its global anti-corruption capabilities.

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DOJ Announces a Pilot Program to Encourage Companies to Self-Report FCPA Violations

On April 5, 2016, the U.S. Department of Justice ("DOJ") released an FCPA "Enforcement Plan and Guidance" memorandum announcing a one-year pilot program that is designed to "motivate[e] companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section, and, where appropriate, remediate flaws in their controls and compliance programs."

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