Compliance Program

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Deferred Prosecution Agreements for the UK – pragmatic solution or approach with caution?

Deferred Prosecution Agreements (“DPAs”), an established part of the legal landscape in the US, are inching ever closer to their long-awaited introduction in England and Wales.  After receiving royal assent via the Crime and Courts Act 2013 earlier this year, a draft Code of Practice (“Draft Code”) explaining how the DPA process will operate is … Continue Reading

German Anti-Bribery and Anti-Corruption Law – An Introduction

Introduction Since the bribery scandals of international magnitude involving German multinational companies like Siemens as well as the local scandals among public officials and politicians, Germany’s enforcement of anti-bribery and corruption law has increased steadily and resulted in significant number of prosecutions and sanctions imposed in domestic as well as in foreign anti-bribery and corruption … Continue Reading

Ministry of Justice confirms that Deferred Prosecution Agreements (“DPAs”) will be introduced in England and Wales

On 23 October 2012, the Ministry of Justice (MoJ) published its response to the consultation paper on DPAs, and confirmed that it will legislate to introduce DPAs in England and Wales.    The Government intends to include an amendment to the Crime and Courts Bill 2012-2013 to introduce DPAs in England and Wales, and it is … Continue Reading

Outline of Resource Guide to the U.S. Foreign Corrupt Practices Act (November 14, 2012)

On November 14, 2012, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) released A Resource Guide to the Foreign Corrupt Practices Act. In its 10 chapters, the Guide provides an overview of the current state of the FCPA as interpreted by the courts, the DOJ and the SEC.  In addition to setting … Continue Reading

Practical Guidance on How to Conduct FCPA Due Diligence

The Department of Justice and Securities and Exchange Commission have stressed the need for companies to conduct FCPA due diligence before entering into transactions with third parties or buying another company.  The DOJ and SEC have levied stiff fines on companies that have not heeded their advice once violations of the FCPA have been discovered.  … Continue Reading

Monthly China Anticorruption Update Report– April 2012

The most recent FCPA and anticorruption enforcement developments involving the People’s Republic of China (PRC) are summarized below.  Thanks as always to Squire Sanders Shanghai office for monitoring and reporting on these enforcement actions. China Enforcement Actions (1) On March 31, 2012, Li Ping, former Party chief of Futian District committee, wassentenced to six-and-a-half years … Continue Reading