Anti-Corruption

Anti-Corruption

J. Scott Maberry, Thaddeus Rogers McBride, Fatema K. Merchant | Sheppard Mullin Richter & Hampton LLP

In the past decade, the U.S. government has interpreted the Foreign Corrupt Practices Act (FCPA) increasingly broadly, especially in cases against non-U.S. defendants. In particular, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have asserted jurisdiction over...

Anti-Corruption

Jonathan Leiken, Theodore T. Chung, Jean-Paul Boulee | Jones Day

Last fall, the U.S. Department of Justice and the Securities and Exchange Commission jointly issued their long-promised “Resource Guidance to the U.S. Foreign Corrupt Practices Act” (the “Guidance”). As we commented at the time, that Guidance, while useful,...

Anti-Corruption

Gregory M. Williams, Richard W. Smith, Christen M. Price | Wiley Rein LLP

As is well recognized, anticorruption investigations can take years to complete and often concern conduct in the distant past. The antibribery and accounting provisions of the Foreign Corrupt Practices Act (“FCPA”) do not specify a statute of limitations. Accordingly, the five-year...