

Individual Liability Continues at a Drip
Despite the DOJ’s repeated emphasis on holding individuals criminally responsible for corporate misconduct, such as the remarks by ...

Gwen Romack
Jun 6, 20242 min read


Ralph Lauren and its Non-Prosecution Agreement reflected FCPA trends
In April 2013, Ralph Lauren Corporation (RLC), the renowned American designer company, entered into a Non-Prosecution Agreement (NPA)[1]Â to

Jeanette Gong
May 9, 20242 min read


2023 TRACE Global Enforcement Report Key Takeaways
TRACE published the 2023 TRACE Global Enforcement Report (GER) last month. This is the 14th annual edition of the report. The document...

Emma Rathmann
Apr 23, 20241 min read


Getting the Message: What to Do (and Worry About) With Ephemeral Messaging Apps and Personal Devices
For companies and their counsel who conduct internal investigations or respond to government requests for documents, dealing with...

Jeffrey D. Clark
Apr 15, 20242 min read


From Red Flag to Case File: How FCPA cases typically come to light
Question: How do FCPA cases typically come to light? Answer: The U.S. Department of Justice and Securities and Exchange Commission both...

David A. Last
Apr 3, 20242 min read


Stericycle, Inc.
On February 27, 2024, Mauricio Gomez Baez, a former Senior Vice President of international waste management company Stericycle, Inc.,...

James Koukios
Mar 28, 20241 min read