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Lessons Learned from the SAP Enforcement Action — DOJ Changes Tack on FCPA Enforcement While SEC Digs into Third-Party Controls (Part III of III) | The Volkov Law Group

A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you.  I know I am scratching my head trying to make sense of the whole picture here.  There are a...
Volkov Law Group Corporate Enforcement Program Volkov Law Third Party Controls

DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II) | The Volkov Law Group

The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to...
Glenn Oztemel Eduardo Innecco Corporate Enforcement Program Volkov Law Group Justice Department Volkov Law

In the Year of the Rabbit, the DOJ Dangles More Carrots to Incentivize Self-Disclosure and Cooperation | Wilson Sonsini Goodrich & Rosati

Whenever a company detects criminal misconduct, it is faced with the difficult decision of whether to self-disclose the misconduct to the federal government. In an attempt to help nudge...
Wilson Sonsini Goodrich Rosati Lisa Monaco Division Corporate Enforcement Policy Division Kennetha Polite Jr Corporate Enforcement Program Us Department Of Justice

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