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Corporate plea deals can be useful as bridge between negligence and criminal behavior, but they should not form part of the SFO’s main arsenal.
Compliance program fixes include addressing use of off-channel comms.
Controversial decisions from the Brazilian Supreme Court continue to undermine the fight against corruption.
SAP SE agreed Wednesday to pay the DOJ and SEC around $222m in penalties to resolve FCPA offenses.
Millions of dollars in bribes were paid to Ecuadorian government officials.
What progress has been made as Brazil tires to implement the OECD Anti-Bribery Convention?