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At the risk of stating the obvious, no company or individual wants to find itself under investigation by U.S. or foreign authorities. A mindset of “getting it wrapped up” naturally assumes top priority status for in-house counsel overseeing any such official inquiry and charged with cabining the inquiry’s business-disrupting impact. In-house and outside counsel, therefore, understandably breathe a sigh of relief when the end appears to be in sight, that is, when (best case scenario) the authorities opt to drop the investigation or when (more likely) the parties ink a non-prosecution agreement (NPA), deferred prosecution agreement (DPA) or old fashioned plea agreement. After all, when the costly ordeal is finally over, isn’t it time to celebrate?

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