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Although it is well-known that companies doing business in the United States can be investigated for violations of U.S. laws and regulations, two unsettling trends have recently emerged. Prosecuting authorities have begun seeking and imposing unprecedented fines for illegal behavior on organizations doing business in the United States. Further, prosecutors are more frequently seeking to bar companies that are found to have committed criminal activity from doing business in or with the U.S. In the article, “Billions in Fines: Just the Tip of the Iceberg,” which appeared in the New York Law Journal on June 19, 2013, Sutherland Partner Ronald Zdrojeski and Associate David McCullough explore the recent trend toward greater enforcement and penalties and discuss best practices for implementing compliance programs.