Photo of Christopher D. Carusone

Christopher D. Carusone is a Partner in the Harrisburg office of Cohen Seglias Pallas Greenhall & Furman PC, 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. With twenty years of experience in the public sector, Chris concentrates his practice in the areas of government law and regulatory affairs, internal investigations, energy and utilities, labor and employment law, and commercial litigation.

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. Continue Reading What In-House Counsel Must Know About the Revised Corporate Enforcement Policy