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Abstract: 

Multi-jurisdictional anti-corruption investigations and prosecutions are on the rise as U.S. regulators increasingly cooperate with their foreign counterparts. In this article, the authors describe the trend and discuss in particular (i) the difficulties raised by variations in anti-corruption laws across jurisdictions; (ii) the tools in the DOJ’s arsenal for collecting evidence abroad; and (iii) the new DOJ policy against the “piling on” of penalties and collateral consequences. They include a number of compliance and defense practice tips and takeaways.

Keywords: Cooperation among Global Regulators; Clarifying Lawful Overseas Use of Data Act (“CLOUD”)

Affiliations:  1: Skadden, Arps, Slate, Meagher & Flom LLP; 2: Skadden, Arps.