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Acquiring Companies of Foreign Interests Risk FCPA Liability

Companies that acquire or invest in offshore entities or in entities that conduct business overseas may inherit FCPA risks. Clearly, the DOJ and the SEC are viewing these transactions and the resulting...

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Defense Bar Strategies May Help Tackle SEC “No Admit” Policy in Parallel FCPA...

Despite recent changes to the SEC’s no admit/no deny settlement policy, FCPA defense attorneys still have options.  As many know, the SEC will no longer allow settling defendants either to admit nor...

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Is The FCPA’s Facilitating Payment Exception Dead?

Incredibly over the last several years, both the DOJ and SEC have been relentless in their aggressive enforcement of the Foreign Corrupt Practices Act.  As part of this pursuit, the FCPA’s facilitation...

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There is No Escape from Whistleblowers Overseas

Alas, the Dodd-Frank whistleblower protections cover informants overseas. The United States Court of Appeals for the Fifth Circuit, recently, held that the Dodd-Frank whistleblower protections cover...

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