Many corporate compliance programs provide a mechanism for providing a “protected” means of reporting compliance concerns to ethics officers, compliance officials, and a range of other designated…
In addition to the expansive application of the Foreign Corrupt Practices Act’s (“FCPA”) anti-bribery provisions associated with the Justice Department’s resolution with J&F Investimentos, S.A. (“J&F”), the…
In terms of the global reach of the FCPA and anti-bribery compliance, the resolution of the U.S. Department of Justice with J&F Investimentos SA (“J&F”), a privately-held…
In terms of issuers and FCPA compliance, the entry of a plea by Jose Carlos Grubisich in response to the Indictment in United States v. Grubisich reflects…
In terms of the Foreign Corrupt Practices Act (FCPA), its prohibitions do not directly address those who solicit or are the recipients of bribes. However, in certain…
In terms of global anti-bribery compliance, the U.S. Department of Justice’s resolution with Deutsche Bank Aktiengesellshaft (“Deutsche Bank”) demonstrates the degree to which the FCPA’s internal control…
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