In order to provide an overview for busy in-house counsel and
compliance professionals, we've summarized below some of the
most important international anti-corruption developments from the
past month, with links to primary resources. This month we ask: How
will new U.S. Department of Justice (DOJ) guidance affect
cash-strapped companies seeking to resolve criminal matters? What
are the latest developments in the investigations into corruption
at Mexico's national oil company? How will a new whistleblower
law affect anti-corruption enforcement in the European Union? The
answers to these questions and more are here in our October 2019
Top 10 list.
1. DOJ Issues Guidance on Corporate Inability-to-Pay
Claims. On October 8, 2019, the Assistant Attorney General
for DOJ's Criminal Division, Brian Benczkowski, issued a memorandum entitled "Evaluating a Business
Organization's Inability to Pay a Criminal Fine or Criminal
Monetary Penalty." The memorandum provides guidance
