Announcement of Policy Revisions Reflects a More Practical, Flexible Enforcement Approach The US Justice Department has adjusted its approach to holding individuals, and not only corporations, responsible for improper conduct. In remarks at the ACI’s FCPA conference on November 29, Deputy Attorney General Rod Rosenstein softened the DOJ’s formal policy…
Richard Dean is a partner in the Firm’s Washington, DC office and focuses on the US Foreign Corrupt Practices Act (FCPA) and related legislation, including US money laundering laws and their application to the activities of global companies in emerging markets such as the former Soviet Union, China, Indonesia and Latin America. Prior to joining Baker McKenzie, Mr. Dean worked at Coudert Brothers’ New York, Sydney, Moscow and Washington, DC offices, and was head of that firm’s Russia and Central Asia Practice from 1988 to 2005. He has an in-depth understanding of the key political, economic and cultural issues facing organizations doing business in these challenging markets.