Subject to Inquiry

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Public companies being investigated by the SEC often face difficult decisions about whether, when, and to what extent they should disclose the government inquiry.  This is especially true in deciding whether to disclose the receipt of “Wells Notices,” which notify recipients that the Enforcement Staff may recommend that the Commission pursue formal charges against the

The RICO suit….reinforces our view that…when defendants become involved in allegations of corruption they may have to face multiple sets of criminal proceedings around the world as well as civil suits and the threat of public procurement debarment in the United States and the European Union. Winning contracts by illegal means can lead to the