Doug Cornelius on compliance for private equity real estate
The Justice Department released a refreshed set of guidelines on how prosecutors should evaluate corporate compliance programs. The Principles of Federal Prosecution of Business Organizations in the United States Attorney’s Manual describe factors that prosecutors should consider in conducting an investigation of a corporate entity, determining whether to bring charges, and negotiating plea or other … Read more »
Lanny Breuer, selected by President Obama to head the Criminal Division of the Justice Department in January 2009, will discuss practical matters for companies dealing with the Justice Department, including topics such as cooperation, attorney-client privilege, and the importance of pre-existing compliance programs. Breuer will also discuss the Department’s increasing use of proactive law-enforcement strategies … Read more »
“The largest single investigation and prosecution against individuals in the history of DOJ’s enforcement of the Foreign Corrupt Practices Act” The Department of Justice has gotten serious about the FCPA. “This ongoing investigation is the first large-scale use of undercover law enforcement techniques to uncover FCPA violations and the largest action ever undertaken by the … Read more »
Republican fundraiser Harry Sargent III is subject to a suit from Supreme Fuels that Sargent’s company International Oil Trading Company made illegal payments to Jordanian officials. IOTC has an exclusinve license to move military fuel through Jordan. IOTC’s response, according to the NBC News Investigates story: . . .in an email to NBC News, a … Read more »
The United States Department of Justice has put together a Lay Person’s Guide to FCPA on the the Department’s site on the Foreign Corrupt Practices Act. The 1988 Trade Act directed the Attorney General to provide guidance concerning the Department of Justice’s enforcement policy with respect to the Foreign Corrupt Practices Act of 1977 (“FCPA”), … Read more »