On Monday, Assistant Attorney General Jonathan Kanter announced significant updates to the DOJ Antitrust Division’s (“the Division”) Leniency Program. While speaking at the joint Federal Trade Commission / Division Enforcers Summit, AAG Kanter explained that with these changes the Division
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A New ‘Economic Crime Bill’ in the United Kingdom to Strengthen Existing Economic Crime Laws
Following a wait of almost five years and expedited due to the UK sanctions announced against Russia, on March 1, 2022, the Economic Crime (Transparency and Enforcement) Bill (the Economic Crime Bill) was laid before the UK Parliament.
The…
In First FCPA Corporate Matter for 2022, SEC Ties Important Aspects of the Resolution to the Company’s Cooperation – and Other Key Takeaways
On February 17, the Securities and Exchange Commission (SEC) announced a settlement with KT Corporation (KT Corp.), South Korea’s largest comprehensive telecommunications operator, for alleged violations (neither admitted nor denied by the company) of the books and records and internal…
OECD Updates Good Practice Guidance for Corporate Compliance Programs and Calls for More Compliance Incentives
As previously reported, on November 26, 2021, the Organisation for Economic Co-operation and Development (OECD) Council issued a Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions (the “2021 Recommendation”).[1] Our blog post…
Key Takeaways from the OECD 2021 Recommendation on Foreign Bribery
The Organisation for Economic Co-operation and Development (OECD) Council issued a Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions (the “2021 Recommendation”) on November 26, 2021. As we reflect on 2021 in terms of US…
DOJ Releases Rare FCPA Opinion, Finding No Corrupt Intent or Business Purpose Where Payment Made Under Duress
Client Advisory: DOJ Overcomes Motion to Dismiss No-Poach Antitrust Prosecution
A federal district court in Colorado last week handed the Department of Justice (DOJ) its second victory in its fight to criminally prosecute allegedly unlawful labor agreements, holding that alleged non-solicitation (or “no poach”) agreements among the defendants and their…
Client Advisory: First Circuit Articulates New Standard for Government Dismissals of Qui Tam False Claims Act Suits
The US Court of Appeals for the First Circuit has added its voice to the split among circuit courts regarding the appropriate standard for deciding government motions to dismiss qui tam False Claims Act (FCA) actions after it has declined to intervene.…
Client Advisory: Ruling in No-Poach/Wage-Fixing Prosecution Opens New Antitrust Frontier
One year after the first criminal indictment for wage-fixing, a Texas federal district court has ruled that an agreement to fix wages is a per se violation of Section 1 of the Sherman Act.
While over the last century the…
World Bank Group 2021 Annual Report on Sanctions System Highlights Enforcement Trends, Key Issues, and Issues Guidance on Integrity Audits
The World Bank Group (the Bank) issued its fourth joint Sanctions System Annual Report on October 18, covering the Bank’s fiscal year from July 1, 2020 through June 30, 2021. The report includes updates by the Integrity Vice Presidency (INT),…