Photo of Christopher D. Carusone

Christopher D. Carusone is a partner in the Cohen Seglias' Harrisburg office where he serves as Chair of the Government Law & Regulatory Affairs and Energy & Utilities Groups, as well as Co-Chair of the Internal Investigations Group. Chris uses his public sector experience and insider knowledge to help companies and individuals solve problems with federal and state government agencies. As Co-Chair of the Internal Investigations Group, Chris conducts confidential investigations for Fortune 500 companies and businesses of all sizes into allegations of waste, fraud, and misconduct within the organization. He also supervises and conducts Title IX and student conduct investigations for schools, colleges, and universities, and is a member of the Association of Title IX Administrators.

This article originally appeared in The Legal Intelligencer on January 02, 2018

On Nov. 29, 2017, U.S. Deputy Attorney General Rod Rosenstein announced a revised Foreign Corrupt Practices Act Corporate Enforcement Policy. The new policy contains a clear roadmap for avoiding corporate criminal liability that corporate counsel would be wise to follow.

The Foreign Corrupt Practices Act of 1977, 15 U.S.C. Section 78dd-1 et seq. (FCPA) makes it unlawful for an “issuer” or “domestic concern” defined by the act to make payments to foreign officials for the purpose of obtaining or retaining business.
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