SAP agreed to pay $220 million to resolve a long-standing foreign bribery investigation with the Department of Justice and the Securities and Exchange Commission involving improper paymen...
The recently enacted Foreign Extortion Prevention Act, meant to serve as the mirror image of the Foreign Corrupt Practices Act, criminalizes the solicitation and receipt of bribes by fore...
In a recent speech, Acting Assistant Attorney General Nicole M. Argentieri laid out how the DOJ is increasing its use of data analytics to proactively identify FCPA cases, deepening its c...
On October 17, 2023, CFTC Director of Enforcement Ian McGinley signaled a more aggressive approach by the agency in new enforcement guidance addressing penalties, admissions, the impositi...
On Wednesday, Deputy Attorney General Monaco announced new DOJ guidance providing a safe harbor to avoid criminal prosecution for companies that identify and disclose misconduct that occu...
Davis Polk partners Dan Kahn and Tatiana Martins and counsel Jordan Leigh Smith authored “Best practices for conducting compliance risk assessments” in Latin Lawyer’s The Guide to C...
In recent speeches, Deputy Attorney General Lisa Monaco and Principal Associate Deputy Attorney General Marshall Miller laid out how the DOJ uses active corporate criminal enforcement and...
Last week, DOJ announced much-anticipated guidance on compensation clawbacks and the use of messaging apps, as well as modifications to its monitorship policies. The guidance provides com...
On February 22, 2023, in their roles on the Attorney General’s Advisory Committee, the U.S. Attorneys for the Eastern District of New York and the Southern District of New York announce...
On January 17, 2023, Assistant Attorney General Kenneth Polite announced changes to DOJ’s corporate enforcement policies, including applying the FCPA Corporate Enforcement Policy to all c...