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The V&E Report
The V&E Report

On January 17, 2020, the United Kingdom’s Serious Fraud Office (“SFO”) published new guidance regarding how the office assesses the compliance programs of organizations that are under investigation…

The V&E Report

January 29, 2020
The V&E Report
The V&E Report

Last week, the U.S. Securities and Exchange Commission (the “SEC”) initiated its third try to pass a rule on “Disclosure of Payments by Resource Extraction Issuers,” 1 which would govern the…

The V&E Report

January 22, 2020
The V&E Report
The V&E Report

The recent bribery conviction of British citizen Lawrence Hoskins created a stir among white collar practitioners because it showed that the US Department of Justice (“DOJ”) could be successful using…

The V&E Report

December 16, 2019
The V&E Report
The V&E Report

On November 7, 2019, a Second Circuit panel 1 heard oral argument on whether the use of United States wire services in effecting a bribery scheme is enough, without more, to pull defendants within…

The V&E Report

November 13, 2019
The V&E Report
The V&E Report

The Criminal Information against two former executives of Unaoil, Inc. was unsealed on October 30, 2019, laying out the U.S. government’s case against them for facilitating bribes on behalf of…

The V&E Report

November 6, 2019
The V&E Report
The V&E Report

Sarah Lawson, the General Counsel of the U.K.’s Serious Fraud Office (“SFO”), recently emphasized that corporate compliance functions must be well resourced and that the SFO expects such programs…

The V&E Report

October 30, 2019
The V&E Report
The V&E Report

The U.S. Commodity Futures Trading Commission (“CFTC”) is entering the fight against foreign bribery and corruption.

The V&E Report

October 10, 2019
The V&E Report
The V&E Report

In a significant departure from previous practice, the Department of Justice (“DOJ”) imposed a corporate monitor on a company even after it engaged in extensive remedial measures and enhanced its…

Published in Law360, June 24, 2019

The V&E Report

June 21, 2019
The V&E Report
The V&E Report

On Monday, March 25, 2019, in a brief order without any dissents, the Supreme Court denied certiorari in In re Grand Jury Subpoena , 1 the case also known as the “Mueller Mystery Case” because the…

The V&E Report

March 27, 2019
The V&E Report
The V&E Report

Last week, the DOJ updated its guidance to the Foreign Corrupt Practices Act (“FCPA”) and in doing so tweaked its de-confliction advice.

The V&E Report

March 20, 2019
The V&E Report
The V&E Report

Last week, the Department of Justice (“DOJ” or “Department”) made a series of changes to the 2017 FCPA Corporate Enforcement Policy (“Policy”) contained in the Justice Manual (until last year, known…

The V&E Report

March 20, 2019
The V&E Report
The V&E Report

DOJ has again modified its guidance regarding enforcement of the FCPA. Among the recent modifications is a loosening of the ban it had announced in 2017 on the use of disappearing messaging…

The V&E Report

March 15, 2019