DOJ

Subscribe to DOJ

This week we are pleased to have a guest post from Edward Heath and Kevin Daly. Attorneys Heath and Daly are members of Robinson+Cole’s Manufacturing Industry Team and regularly counsel clients on trade compliance, anti-corruption compliance, and other corporate compliance issues.

It would be a mistake to think that the $2.9 billion settlement Goldman Sachs Group Inc. has agreed to pay in order to resolve allegations of widespread bribes to government officials in Malaysia and the United Arab Emirates has no relevance to those in the manufacturing industry. Although the settlement did involve a financial services firm, the underlying facts highlight important considerations for manufacturers with respect to the U.S. Foreign Corrupt Practices Act (FCPA).

The FCPA is the federal law that prohibits U.S. companies from paying, offering, or promising anything of value to a foreign government official in order to obtain or retain business opportunities. The DOJ and SEC share enforcement authority for the FCPA, and it is a major enforcement priority for both agencies. Total FCPA recoveries for the U.S. government total in the hundreds of millions of dollars annually, and in some years exceed $1 billion. The Goldman Sachs settlement is the largest FCPA settlement ever.…
Continue Reading Historic $2.9 Billion Anti-Bribery Settlement Has Important Takeaways for Manufacturers

Below in an excerpt from an article authored by Robinson+Cole Manufacturing Industry team lawyers Edward J. Heath and Kevin Daly with Sasha Glassman, assistant general counsel for global materials manufacturing company Rogers Corporation, that was published on ACCDocket.com.

On June 1, 2020, the Criminal Division of the United States Department of Justice (DOJ) issued a…

This week, we are pleased to have a guest post from Kevin Daly.  Attorney Daly is a member of the firm’s Manufacturing Industry Group and also its Trade Compliance Team.

The Foreign Corrupt Practices Act (“FCPA”) prohibits paying or offering bribes to foreign officials to obtain business advantage. In some instances, the paying or offering of bribes prohibited by the FCPA may involve multiple electronic communications sent over time. A federal court in New Jersey recently considered the novel issue of whether multiple communications in furtherance of a single bribe can be charged as multiple offenses under the FCPA.…
Continue Reading DOJ’s Latest FCPA Pressure Tactic: Charging Multiple Violations for Single Alleged Payment Scheme

This week we are pleased to have a guest post from Edward Heath and Kevin Daly. Attorneys Heath and Daly are members of Robinson+Cole’s Manufacturing Industry Team and regularly counsel clients on trade compliance, anti-corruption compliance, and other corporate compliance issues.

 Last week, a jury found a former executive of a French multinational company guilty of violating the Foreign Corrupt Practices Act, money laundering, and conspiracy in connection with alleged bribery in Indonesia. The case is a significant test of the geographic reach of the FCPA because the defendant was a foreign national who was employed by a foreign corporation and never entered U.S. territory during the course of his employment, but he was convicted on the theory that his actions were taken as an agent for his employer’s U.S. subsidiary.…
Continue Reading Conviction of Foreign Employee Reinforces Broad Geographic Reach of FCPA

This week we are pleased to have a guest post from Edward Heath and Kevin Daly.  Attorneys Heath and Daly are members of Robinson+Cole’s Manufacturing Industry Team and regularly counsel clients on trade compliance, anti-corruption compliance, and other corporate compliance issues.

Earlier this year, the United States Department of Justice (DOJ) issued new guidance…

The post below is a follow-up to an earlier post written by my colleagues, Edward Heath and Kate Dion. Edward is my partner and is Chair of Robinson + Cole’s White-Collar Defense and Corporate Compliance Practice. Kate is a litigation associate who routinely handles government and internal investigations for manufacturing clients.

In the…