Tag: cooperation

Privilege In Government Investigations: The Walmart FCPA Case

The attorney-client privilege serves the long, well-established goals of encouraging full and frank disclosure between an attorney and client, thereby promoting the public interest as the Supreme Court held in UpJohn v. U.S., 449 U.S. 383 (1981). Equally clear is

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The SEC, Insider Trading and Cooperation

Insider trading has long been a staple of the Commission’s Enforcement program. Cooperation credit, while frequently touted and often discussed is not, at least in the form of a deferred prosecution agreement. Rather, the awarding of cooperation credit is typically

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