Sigal Mandelker
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The U.S. Department of Justice recently publicized its second Foreign Corrupt Practices Act Opinion Procedure Release of 2014. In the Release, the DOJ reiterated that an acquiring company may not inherit FCPA liability when the DOJ did not have jurisdiction over the target company’s prior corrupt activities. The DOJ has repeatedly asserted that, through principles … Continue Reading
2014 was a banner year for federal recoveries under the False Claims Act (“FCA”). In a press release dated November 20, 2014, the DOJ announced that its total recoveries – including those from both settlements and judgments – amounted to $5.69 billion for the fiscal year ending September 30th. These results mark the first time … Continue Reading
Attorney General Eric Holder and Principal Deputy Assistant Attorney General for the Criminal Division Marshall Miller have sent the message that the Department of Justice is looking to hold individuals responsible for corporate crime. Holder, speaking at New York University, announced that the department is currently investigating the conduct of individuals at certain financial institutions … Continue Reading
SEC v. Graham, No. 13 Civ. 10011 (KLG), 2014 WL 1891418 (S.D. Fla. May 12, 2014), a recent decision by the Southern District of Florida, may be a dagger in the heart of the SEC’s long-standing position that the five year statute of limitations imposed by 28 U.S.C. § 2462 does not apply to actions … Continue Reading
Recently confirmed Assistant Attorney General of the U.S. Department of Justice Criminal Division, Leslie Caldwell, has laid out her views as to what comprises the “hallmarks of good compliance programs.” In her new position, AAG Caldwell will repeatedly be in the position to decide whether corporate compliance programs are sufficient when making charging and settlement … Continue Reading
DOJ Releases Second FCPA Opinion of 2014
By Sigal Mandelker and Phillip Caraballo-Garrison on Posted in White Collar
DOJ Announces Record Year of Over $5 billion in False Claims Act Recoveries
By Sigal Mandelker, Jonathan Siegelaub and Roger Cohen on Posted in Corporate Governance, Health Care, White Collar
Companies and Individuals Alike Should Heed DOJ’s Focus on Individual Liability
By Sigal Mandelker, Jessica Fisher and Phillip Caraballo-Garrison on Posted in SEC Enforcement, White Collar
SEC May Be Forced to Adhere to a Five Year Statute of Limitations for all Actions
By Sigal Mandelker and Jessica Fisher on Posted in SEC Enforcement, White Collar
AAG Caldwell Provides Guidance on Adequate Compliance Programs
By Sigal Mandelker and Jason Richman on Posted in Corporate Governance, White Collar
