In this episode I visit with Mark Lanpher, a partner at Shearman & Sterling LLP, practicing in the firm’s White Collar and Regulatory Enforcement group. Lanpher is a former Assistant Chief Litigation Counsel at the SEC. We take a deep dive into the July 2018 change in FCPA Enforcement Policy, announced by the Justice Department creating a safe harbor in mergers and acquisition enforcement actions brought under the FCPA. Some of the highlights from the podcast include:

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1.    How did Matthew Miner’s announcement impact the FCPA Corporate Enforcement Policy re: M&A?
2.    What were the policy reasons behind the announcement?
3.    Was Miner’s announcement a codification of DOJ/SEC safe harbor policy first articulated in the 2012 FCPA Guidance?
4.    How did (or not) Miner’s announcement bring certainty to this area?
5.    What does it mean going forward?

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