As the frequency of international cooperation and multilateral settlements has increased, so has the question of whether the total “pie” of possible criminal penalties is getting bigger, essentially subjecting companies to international double jeopardy for the same acts of bribery. At a recent panel, experts from Argentina, the Netherlands, Belgium and the U.K. discussed international cooperation, global settlements and the double-jeopardy risks for multinational companies caught in the anti-corruption crosshairs. See “How Significant Is the DOJ’s New Directive on Coordination?” (May 16, 2018).
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