Daily Archives: April 23, 2011, 1:00 pm

What Does Effective FCPA Compliance Look Like?

Last week, Johnson & Johnson entered into a deferred prosecution agreement with the Justice Department for violating the Foreign Corrupt Practices Act (FCPA). Although the agreement has been touted as novel for the reduced fine J&J received in exchange for cooperating against other companies and individuals, the agreement confirms the importance of assessing FCPA policies and internal controls. Companies continue…

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Deconstructing the Galleon Insider Trading Case

The prosecution of Mr. Rajaratnam is not an isolated fight but rather part of an ongoing doctrinal war pitting the rather extreme views of the Securities and Exchange Commission against the carefully considered law of insider trading articulated by the Supreme Court. The SEC does not draw a distinction between trading on the basis of legitimate albeit unorthodox research and…

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