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Perhaps in this current time of crisis and unprecedented government response, it is as important now as at any time that citizens trust that government officials’ decisions are made free of improper influence or self-dealing. Federal, state, and local decision-making will undoubtedly and significantly affect every aspect of our lives and work. While community vigilance beyond law enforcement efforts is required to maintain public integrity, federal prosecutors nevertheless have a “wide berth” to combat corruption by elected and appointed officials. United States v. Rosen, 716 F.3d 691, 694 (2d Cir. 2013).
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By Jonathan B. New, Jimmy Fokas, Patrick T. Campbell and Bari R. Nadworny
In recent months, the Dept. of Justice has raised expectations for companies to use data analytics to monitor the effectiveness of their compliance programs and to identify potential misconduct.
The Potential for Fraud or Misbehavior In the Time of COVID-19
By ljnstaff
A roundtable discussion on the topic of government investigations, corporate compliance efforts, and the potential for fraud or misbehavior in the time of COVID-19.
Particularized Pleading of Underlying Illegal Acts in the Second Circuit
By Steven Paradise and Matthew Catalano
Gamm v. Sanderson Farms, establishes a high burden for a plaintiff to plead adequately failure to disclose illegal conduct — regardless of how much circumstantial evidence a plaintiff is able to amass or how much news coverage the alleged conduct attracts.
The Updated FCPA Resource Guide
By Jacqueline C. Wolff
Something Old, Something New, Something Borrowed, Something Blue
this second edition contains some new “hypotheticals” — facts of actual cases the DOJ finds important enough to focus on — and, in keeping true to its name, has included additional resources and links for chief compliance officers looking to design and audit their companies’ anticorruption compliance programs.
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