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Earlier this year, the Singapore Parliament passed the Criminal Justice Reform Act 2018 (the Criminal Justice Act) introducing, among other things, a formal legislative framework for the Public Prosecutor to enter into deferred prosecution agreements (DPAs) with corporate offenders to resolve misconduct. This change represents a significant shift in Singapore’s approach towards corporate wrongdoing, and aligns Singapore more closely with global trends. Here are five things you should know about this development: Singapore’s new DPA…
Over the last few months, US economic sanctions have taken the front pages as the Trump Administration has reinstated certain sanctions aimed at Iran following the United States withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”). While the so-called “snapback” reinstated sanctions provisions increase the risk for non-US companies, recent enforcement actions against non-US companies demonstrate that such companies have always been at risk of violating the US sanctions laws.…
On October 25, 2018, John Cronan, Principal Deputy Assistant Attorney General of the Criminal Division of the US Department of Justice (DOJ), delivered an important speech that touched on several key issues for legal and compliance counsel trying to balance business realities with regulator expectations, particularly with respect to compliance with the US Foreign Corrupt Practices Act (FCPA).[1] Of particular note, Cronan discussed: The application of the DOJ’s FCPA Corporate Enforcement Policy; The DOJ’s…
On April 5, 2016, the DOJ announced a new Foreign Corrupt Practices Act (FCPA) enforcement pilot program with the goal of motivating companies to voluntarily self-disclose FCPA-related violations, to fully cooperate with the DOJ during investigations, and to promote greater accountability for individuals and corporations who violate the FCPA and related laws. Under the program, a company that: (1) voluntarily self-discloses a suspected violation; (2) fully cooperates with the DOJ on all aspects of the…