Marcus A. Haggard

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The U.K. Modern Slavery Act of 2015 requires companies falling under its jurisdictional hook to honestly and completely disclose their efforts to eradicate trafficked, slave, indentured, coerced and child (collectively “forced”) labor from their supply chains. This, like many things in the compliance world, is easier said than done.  As discussed in this Client Update, only a small percentage of companies have implemented disclosures that fully meet the letter (or spirit) of these laws. Read
In United States v. Hoskins, 902 F.3d 69 (2d Cir. 2018) the Second Circuit held that a non-resident foreign national cannot be criminally liable for aiding and abetting or conspiring to violate the FCPA unless the government can establish that such an individual acted as an agent of one of the categories of persons subject to liability as a principal. Background The DOJ charged Lawrence Hoskins, a British national and former Alstom UK executive based…