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FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.” Set forth below are the topics discussed this week on FCPA Professor. As highlighted here, the DOJ and SEC quietly released a Second Edition of “A Resource Guide to the Foreign Corrupt Practices Act” (FCPA Guidance). As highlighted here, Alexion Pharmaceuticals agreed to approximately $21.5 million to…
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As highlighted in prior posts here, here, and here, in November 2012 the DOJ and SEC released “A Resource Guide to the Foreign Corrupt Practices Act” (FCPA Guidance). The release was accompanied by DOJ and SEC press releases as well as a press conference. Today, a Friday of a holiday weekend the DOJ and SEC quietly released a Second Edition of the FCPA Guidance. Like the original guidance, the Second Edition contains…
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Yesterday, the SEC announced that Alexion Pharmaceuticals (a company that has been under scrutiny since mid-2015) agreed to approximately $21.5 million to resolve an enforcement action based on the actions of foreign subsidiaries involving the company’s primary drug Soliris. The conduct at issue focused on Alexion Illac Ticarent Limited Sirketi (Alexion Turkey), Alexion Pharma OOO (Alexion Russia), Alexion Pharma Brazil and Alexion Pharma Colombia SAS (all wholly-owned subsidiaries whose books and records were consolidated into…