Extra-Territorial FCPA and Fraud Enforcement: Clarifying “Agency,” and DOJ and SEC Compliance Programme and Internal Controls Expectations
- Update on investigations and prosecutions amid Covid-19
- “Agency” post-Hoskins: The scope of individual liability risks for non-US citizens or entities
- How the agencies evaluate “cooperation”: Trends in what meets the threshold and what doesn’t
- When a company’s actions are enough to trigger favourable treatment under the policy vs. "aggravating circumstances,": Is there a difference between SEC and DoJ analyses?
- Evaluation of Corporate Compliance Programmes: DoJ insights on how to interpret and apply the Guidance
- Monitorships: Expectations of the agencies and application of DoJ’s policy
- Voluntary Disclosures: Is DoJ continuing to see an increase in self-disclosures post-Pilot Program?
- Insights on privilege and disgorgement
- How the SEC and DOJ coordinate with foreign governments