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Publication of the First Final US Export
7 May 2013
Publication
The first set of final Export Control Reform rules should have caught no one by surprise given the steady drumbeat since 2009 announcing the US government's intent to rethink its entire approach to protecting sensitive US technology. These new rules, published...
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Pulibcation of the first Final US Export Control Reform Rules: Don't be surprised, be prepared
3 May 2013
Publication
The first set of final Export Control Reform rules should have caught no one by surprise given the steady drumbeat since 2009 announcing the US government's intent to rethink its entire approach to protecting sensitive US technology. These new rules, published...
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Myanmar Sanctions: Unlike Anything You Know About
27 February 2013
Publication
Rudyard Kipling’s description of the land of Burma in 1898 aptly describes the landscape of US sanctions on the country 115 years later. Those sanctions, imposed since 1988, have been lifted, suspended, and waived over the last year in a systematic effort...
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China Releases New Judicial Interpretation on Offering Bribes
1 February 2013
Publication
On 26 December 2012, important guidance was provided by the Supreme People’s Court ("SPC") and the Supreme People’s Procuratorate ("SPP") on how China's criminal bribery law is interpreted. The SPC and SPP jointly promulgated...
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The Asia Pacific Top Ten FCPA Enforcement Actions of 2012
24 January 2013
Publication
The Asia Pacific region remained a hotspot for US anti-corruption enforcement authorities in 2012. Six of the twelve corporate Foreign Corrupt Practices Act (FCPA) settlement agreements in the past year involved business operations in that region. In addition...
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Observations on the M&A Strategies of Multinationals in China's Pharmaceutical Market in 2012
8 January 2013
Publication
Recent years have seen acquisitions become a common element of any growth strategy for multinationals engaged in China's pharmaceutical market. At least half of the top 10 multinationals in China appear to be actively pursuing one or more targets with...
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Asia Pacific Anti-Corruption Rankings for 2012
19 December 2012
Publication
Transparency International’s recently released Corruption Perceptions Index 2012 reveals important new data for companies operating in Asia Pacific. There is some improvement and some backsliding amongst the countries reviewed, but with only one exception,...
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Ten Hallmarks of Effective Compliance Programs for Asia Pacific Companies
13 December 2012
Publication
Designing a corporate anti-corruption compliance program for companies operating in Asia Pacific sometimes feels like trying to fit a round hole around a square peg. No amount of pounding will smooth the edges off a thousand years of guanxi.
Fortunately, perhaps...
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Was It Worth the Wait? The Department of Justice / Securities Exchange Commission Guidance on the FCPA
14 November 2012
Publication
Today, the U.S. Department of Justice ("DOJ") and the U.S. Securities and Exchange Commission ("SEC") (collectively, the "Agencies") released "A Resource Guide to the U.S. Foreign Corrupt Practices Act" (the "Guide"). ...
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Minimising corruption risk from counterparties in the natural resources sector
5 November 2012
Publication
As regulators and prosecutors around the world increase their efforts to combat corruption and bribery, companies need to monitor the actions of third parties as closely as those of their own employees.
Natural resources companies are used to operating in difficult...