• 09.21.15

    New DOJ Policy Alert: Here's Looking at You, Kid

    On September 9, 2015, Deputy Attorney General Sally Quillian Yates issued a memo to all DOJ department heads and U.S. Attorneys which detailed the Government's new policy centered on accountability for the individuals who are alleged to have perpetrated corporate misconduct.

  • 09.08.15

    No Dog Days of August for the SEC—a Recap of A Busy Month

    Who says there is a government slowdown in August?

  • 08.05.15

    Are the Circuits A-Splitting?

    On July 6, 2015, the Ninth Circuit in U.S. v. Salman declined to adopt a narrow interpretation, arguably set by the Second Circuit in U.S. v. Newman in 2014, of the "personal benefit" element of insider trading cases.

  • 06.30.15

    The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card?

    The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing organization, but FIFA remained seemingly impervious . . . until now.

  • 05.29.15

    It’s an Absolute Privilege to Meet You!

    On May 15, 2015, the Texas Supreme Court ruled that an internal investigation report provided by Shell Oil Company to the DOJ in 2009 in connection with an FCPA investigation enjoys “absolute privilege” and therefore cannot be the basis for a defamation case against the company.

  • 04.21.15

    It’s Stifling in Here!

    On April 1, 2015, the SEC announced its first-ever enforcement action against a company for using restrictive language in confidentiality agreements with witnesses interviewed during internal investigations that has the potential to improperly stifle whistleblowers and impede the whistleblowing ...

  • 03.19.15

    The SEC’s Settlement with Goodyear: A Cautionary Tale

    In a settlement announced on February 24, 2015, the SEC found Goodyear to be in violation of the FCPA in connection with bribes paid by two foreign subsidiaries, one of which came into Goodyear’s ownership through acquisition.

  • 10.28.13

    Mapping The New Fraud And Abuse Landscape

    In an age of increased government scrutiny and enforcement, providers, payers, pharmaceutical companies and medical device manufacturers, along with their business partners, must be mindful of the fraud and abuse laws regulating their business operations.

  • 11.15.12

    The New FCPA Guidance

    The Department of Justice and the Securities and Exchange Commission have jointly issued long-awaited guidance on their interpretation and enforcement of the U.S. Foreign Corrupt Practices Act. 

  • 07.12.12

    Banks at Risk: Foreign Corrupt Practices Act Allows Seizure of Customer Bank Accounts

    Banks are vulnerable to seizures of customer assets by the U.S. Government.

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