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The CROOK Act: Tackling Demand-Side Bribery

Abigail Bellows with the Carnegie Endowment for International Peace describes how a $5 million surcharge could be levied on FCPA enforcement actions and then deployed quickly to support incipient anti-corruption efforts worldwide. This would address, in part, concerns that the victims of corruption rarely benefit from the substantial sums involved in settlements.

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Commercial Intermediaries Are Not the (Only) Problem

Mike Ward, partner at Vinson & Elkins in San Francisco and former chief compliance officer with Juniper Networks, discusses the overstated role attributed to business partners as the sole conduit of corruption. Mike also addresses the widely misunderstood role that agents, distributors and channel partners play, and why companies often need to work through these sales and marketing networks to go to market worldwide.

Timely Topics

Compliance During COVID-19

Kara Brockmeyer, a partner in Debevoise & Plimpton&rsquos Washington, D.C. office and former Chief of the SEC&rsquos FCPA Unit, discusses some changes she&rsquos observed in the implementation of compliance programs with much of the world in lockdown. She also describes the pace of investigations now that DOJ and SEC lawyers are working remotely, and she wraps up with a few predictions about what we might see in this field post-pandemic.

Timely Topics

U.S. National Security, CFIUS and COVID-19

Darshak Dholakia, a partner in Dechert&rsquos Washington, D.C. office, provides a timely overview of the current Committee on Foreign Investment in the United States (CFIUS) approach to foreign investment in the U.S., comparable laws of other countries, and how scrutiny of health care and biotechnology sectors may increase in light of the COVID-19 pandemic.

Timely Topics

The Impact of COVID-19 on the Movement of Goods Internationally

Melissa Duffy, a partner at Dechert LLP focused on international trade matters, provides an excellent review of the current status of the movement of goods into and out of the United States by air, land and sea. Melissa also addresses relevant tariffs, including recent exemptions, and restrictions by other countries on the export of their own critical medical supplies and equipment. Melissa wraps up with some very practical strategies for companies on managing the movement of goods in these uncertain times.

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