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New DOJ Guidance Reflects an Evolution in the Evaluation of Corporate Compliance Programs

On April 30, 2019, the DOJ's Criminal Division published an updated Evaluation of Corporate Compliance Programs Guidance Document (“the Guidance”) for prosecutors to use in evaluating corporate compliance programs.

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Two Recent Decisions Provide Rare Guidance on the FCPA's Reach Over Foreign Nationals


Time to Read: 1 minutes Practices: Anti-Corruption / International Risk, Government Enforcement / White Collar Criminal Defense

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Two recent district court decisions have shed light on the reach and scope of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign nationals: SEC v. Straub and SEC v. Sharef. For companies and individuals operating abroad, these cases provide rare judicial guidance on the reach of the FCPA’s anti-bribery and record-keeping provisions. Together, they reaffirm U.S. regulators’ long-standing position that the FCPA has broad applicability to foreign nationals, while also setting the outer limits of the civil scope of the FCPA.

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