A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded.
On March 26, 2020, as government officials issued a slew of stay-at-home orders, the U.S. Environmental Protection Agency (EPA) published an emergency policy memorandum describing how the agency would exercise its enforcement discretion during the COVID-19 crisis.1
On July 3, 2020, the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) published the Second Edition of “FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act” (the “Guide”).
Government contractors operate in a constantly changing regulatory environment, and in certain circumstances, a contractor may be contractually entitled to receive a price adjustment when it must comply with a new federal law during performance.
The U.S. Department of Justice (DOJ) has a track record of aggressively pursuing those suspected of fraudulently exploiting federal relief programs meant to combat crises,1 and early signs indicate that DOJ will continue this practice with the current COVID-19 pandemic.
In a little-noticed move yesterday, the U.S. Department of Justice (“DOJ” or “Department”) quietly amended its most important guidance document on corporate compliance.
A recent decision out of the Southern District of New York emphasizes the importance of considering all obligations under the federal securities laws for any transaction that might involve a “security.”
The COVID-19 pandemic has caused enormous pain and financial harm and it will take months, or even years, before we know its full impact.