Our offices are being searched by law enforcement officers. Do
not obstruct the search. The officers have a legal right to certain
items and documents related to the warrant.
We are complying with the warrant. You should be cooperative
and assist law enforcement in locating relevant files. However,
please do not "consent" to any search or sign any
documents on behalf of the company.
For example, if an officer asks where documents are located,
feel free to show her. On the other hand, if the officer asks you
how the documents were created or what they mean, you are under no
obligation to answer. Merely show the officer the documents without
Please refrain from using social media (Twitter, Facebook,
etc.) to disseminate any information about law enforcement's
presence at our Company.
Any questions from the press should be immediately referred to
[ ]. Do not make any statement other than "Please call [ ]
about this matter."
Law enforcement officers may ask you to answer their questions.
It is your choice whether to submit to an interview. You are under
no legal obligation to do so; but if you choose to respond, the
Company's lawyers have a right and have requested to be present
at any interview with a company employee.
If you do grant an interview to the investigating officers,
anything you say can be used against you in a criminal prosecution
or in a civil enforcement proceeding. If you decide to be
interviewed please inform the agents of the company's request
for its lawyers to be present.
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary resources.
The DOJ is creating a new compliance counsel position in the Criminal Division's Fraud Section to scrutinize the compliance programs of companies under investigation for possible Foreign Corrupt Practices Act (FCPA) violations.
When renowned violin master and teacher Roman Totenberg passed away in 2012 at the age of 101, he died believing that his treasured Stradivarius violin was stolen following a 1980 performance in Cambridge, Massachusetts, and that it would never be recovered.
On August 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International, Inc.) pleaded guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act.
In the past year, a number of major financial institutions have
been hit not just once, but twice by federal and state regulators
for follow-on regulatory violations, including financial sanctions