In this Special Report from the New York Law Journal: "The Disappearing Exception for Facilitating Payments," "N.Y.'s Organized Crime Control Act After 25 Years," "Combatting Intercepted Co-Conspirator Statements With FRE 806" and "2012 Saw an Increase in Enforcement Against Banks."
February 11, 2013 at 12:00 AM
1 minute read
View the Digital Edition of this Special Report.
Kevin J. Harnisch, Steven M. Witzel and Joshua D. Roth of Fried, Frank, Harris, Shriver & Jacobson examine the evolution of the "facilitating payments" exception to the Foreign Corrupt Practices Act, the new DOJ/SEC Guide’s treatment of that exception, and the extent to which such payments remain permissible.
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