Tag Archives: Ralph Levene

FCPA Declination Highlights the Importance of Pre-Acquisition Due Diligence and Post-Acquisition Compliance Integration

by John F. Savarese, Ralph LeveneMarshall L. Miller, and Jonathan Siegel

As we have observed, in its early days, the Trump Administration has stressed its intention to maintain continuity in white-collar enforcement, including through its recent extension of the FCPA Pilot Program. Consistent with that approach, the first FCPA action under the new administration was a Pilot Program declination, closing an investigation without enforcement action other than disgorgement. Continue reading