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Entries in Matthew Tannin (1)

Tuesday
Aug062013

SEC’s New Admission Policy: What it Means for FCPA Cases

In 2012, the SEC announced that it would no longer enter into “neither admit nor deny” settlements with companies or individuals who had admitted relevant facts in parallel DOJ dispositions. Since then, the SEC has made good on that promise by requiring such factual admissions in resolving FCPA cases, but only to the extent covered by the DOJ pleadings -- implicitly leaving other allegations under the usual neither admit nor deny approach.

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