Criminal Enforcement of Environmental Laws The Internal Investigation: Cooperation and the McNulty Memorandum Part I: The Other Internal Investigation Part II: Examples of Declinations, Non-Prosecutions and Deferred Prosecutions Fourteenth Annual Advanced ALI - ABA Course of Study for the Defense and Government Bars October 4 & 5, 2007 Presented by Barry M. Hartman, K&L Gates
Jazz Pharmaceuticals No Pros Unilateral pre-settlement corporate actions Guarantee subsidiaries criminal payment obligations to insurers Cooperate Corporate Integrity Agreement
United Bank for Africa No prosecution Obstruction of money laundering investigation New management Witness available No new incidents
Electronic Clearing House No Pros Cooperation Disgorgement of profits Remedial actions
Pacific-Gulf Marine No Pros Discharge of oil bilge waste Voluntary/timely disclosure of internal investigation $500,000 in restoration projects
American Express Bank International Deferred Pros (AML) $55 Million forfeiture Significant remedial actions
Maximus Deferred Pros (FCA) Medicaid Fraud $30.5 Million Penalty
NETeller PLC Deferred Pros Internet gambling $136 Million forfeiture Remedial and monitoring measures
Mirant Energy Deferred Pros (CEA) Extensive Cooperation and Disclosure Bankruptcy
Criminal Enforcement of Environmental Laws The Internal Investigation: Cooperation and the McNulty Memorandum Part I: The Other Internal Investigation Part II: Examples of Declinations, Non-Prosecutions and Deferred Prosecutions Presented by Barry M. Hartman, K&L Gates barry.hartman@klgates.com
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