On November 29, 2017, the U.S. Department of Justice (“DOJ” or the “Department”) announced a new FCPA Corporate Enforcement Policy (the “Enforcement Policy”) applicable to investigations of companies under the Foreign Corrupt Practices Act (“FCPA”). The Enforcement Policy builds on the FCPA Pilot Program (the “Pilot Program”) that has been in effect since April 2016,
Hong Kong SFC and HKMA Issue New Guidelines for Reducing and Mitigating Hacking Risks Associated with Internet Trading
On October 27, 2017, the Hong Kong Securities and Futures Commission (“SFC”) issued Guidelines for Reducing and Mitigating Hacking Risks Associated with Internet Trading (the “Guidelines”),1 a set of baseline cybersecurity requirements that all persons licensed or registered with the SFC and engaged in internet trading will be required to implement. The Hong Kong Monetary
Second Circuit Decision Reiterates The Limitations of Joint Defense Agreements
On August 18, 2017, in United States v. Krug, the Second Circuit revisited the boundaries of attorney-client privilege in the context of joint defense agreements, reversing a district court order to preclude testimony of a cooperating co-defendant. The decision serves as a useful reminder of certain best practices when participating in joint defense (or “common interest”) agreements to ensure that the communications are protected by the privilege.
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