Anti-Corruption
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Anti-Corruption
Managing Distributors and Third-Party Intermediaries: Coping with the long arm of FCPA enforcement
MCC: Starting with the basics. How do you define a “third-party intermediary”? McCann: Most companies struggle with the simple definition of a third-party intermediary (“TPI”) as they evaluate their intermediary relationship populations and the associated risks. One of...
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Supreme Court Declines to Review 3rd Circuit Ruling; Crime-Fraud Exception to Attorney-Client Privilege Decision Persists
On November 10, 2014, the Supreme Court (No. 14-389) declined to review the 3rd Circuit decision (No. 13-1237), In Re: Grand Jury Subpoena, leaving intact the 3rd Circuit’s ruling on the proper bounds of the crime-fraud exception to the attorney-client privilege. In the...
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Federal Appellate Court Issues Broad Interpretation Of Term “Instrumentality” Under FCPA
On Friday, May 16, 2014, the U.S. Court of Appeals for the Eleventh Circuit issued a significant ruling addressing the definition of the term “instrumentality” as used in the Foreign Corrupt Practices Act of 1977 (the “FCPA”). United States v. Joel Esquenazi and Carlos...
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