Law360, New York ( November 23, 2015, 10:41 AM EST) -- Recent guidance by the U.S. Department of Justice reveals that the government may leverage "cooperation credit" under the "Principles of Federal Prosecution of Business Organizations"[1] (authored by former Deputy Attorney General Mark Filip, i.e., the "Filip memorandum") to obtain foreign-based information that is outside the scope of a federal grand jury subpoena. And, while this issue was recently previewed in the anti-corruption and anti-bribery context, there is no reason to believe that it may be so limited going forward....
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