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Archive for Declinations category:

The Head of DOJ’s Fraud Section Speaks

On February 9, 2016, Andrew Weissmann, the head of DOJ’s Fraud Section, provided an informative keynote speech at a conference sponsored by the Global Investigation Review in Washington, D.C. Below is a summary of some of the main topics addressed. List of compliance questions. Weissmann said that the DOJ will publish in the next weeks a […]

Author: Carlos Ayres

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A Boost in FCPA Declinations? Why FCPA enforcement has fallen this year

This year, FCPA enforcement authorities have brought only eight resolved enforcement actions, the lowest mid-year total in a decade. Why the slowdown? Does it represent a fundamental shift in FCPA enforcement? Miller & Chevalier’s FCPA Summer Review 2015 suggests that the answer is no, and explains why. The report cites an increase in the number […]

Author: Matteson Ellis

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FCPA Voluntary Disclosure Considerations

Neither a company nor its directors or officers have an affirmative obligation under the FCPA to disclose knowledge of a violation. But enforcement officials stress that there are benefits to doing so, including more lenient treatment and credit when penalties are calculated. Recently, outgoing DOJ Fraud Section Chief Jeffrey Knox said in an interview with […]

Author: Matteson Ellis

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FCPA Opinion Procedure Releases – An Oft-Forgotten Resource

At the end of 2013, the DOJ issued its only Opinion Procedure Release of the year. A law firm partner used the opinion process to ask whether he or she would violate the FCPA by paying the medical expenses of the daughter of a foreign official of a country that his firm represented. The official’s […]

Author: Matteson Ellis

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Voluntary Disclosures, through the Eyes of FCPA Enforcement

When James Cole, Deputy Attorney General of the United States, gave his keynote address at ACI’s 30th International Conference on the FCPA, he dedicated an inordinate amount of time to the issue of self-disclosures of FCPA violations. “We at the Department are committed to demonstrating the benefits to your working cooperatively with us,” he said. […]

Author: Matteson Ellis

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