Court Orders Opening of Pandora's Box
Client Alert | 1 min read | 03.12.14
In U.S. ex rel. Barko v. Halliburton Co. (D.D.C. Mar. 6, 2014), the court ordered the defendants in a qui tam FCA case to produce internal reports and other documents that were prepared during the course of internal investigations initiated in response to "tips" regarding potential misconduct, even when the tips were made directly to the defendants' Law Department, the reports were transmitted to the Law Department, and the investigations were initiated and managed by senior in-house attorneys. The court concluded that the materials were not protected by the attorney-client privilege because the investigations were "undertaken pursuant to regulatory law and corporate policy"— i.e., the contract clause required by the FAR Mandatory Disclosure rules, which set forth requirements for a contractor's code of business ethics and conduct, compliance program, and internal controls system—"rather than for the purpose of obtaining legal advice," and that they were not protected by the work product doctrine because they were not prepared in anticipation of litigation.
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Client Alert | 3 min read | 02.10.26
UK FCA Proposes New Sustainability Disclosure Rules for Listed Companies
The UK Financial Conduct Authority (FCA) recently issued consultation paper CP26/5, proposing to replace the existing Task Force on Climate-related Financial Disclosures (TCFD) requirements with new rules mandating listed companies to report against the UK Sustainability Reporting Standards (UK SRS). These are based on the IFRS Sustainability Disclosure Standards developed by the International Sustainability Standards Board (ISSB).
Client Alert | 3 min read | 02.09.26
Client Alert | 1 min read | 02.09.26
Worried Three’s a Crowd? Decline Intervention at Your Own Peril
Client Alert | 4 min read | 02.05.26
EU–Brazil Mutual Adequacy: A Milestone for Global Data Flows and Latin America’s Digital Positioning

