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Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Elizabeth K. Spahn Editor Emeritus

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

Entries in Cooperation (45)

Thursday
May172018

Covington and Hantman: New DOJ policy against piling on has rewards, with strings attached

A common refrain in the white collar bar is that American government agencies don’t often get along and play well together. This can result in challenging issues for companies doing business in the United States that have run afoul of the law.

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Thursday
May102018

DOJ rolls out new policy against ‘piling on’ 

Deputy Attorney General Rod Rosenstein announced a new policy Wednesday that encourages coordination among DOJ departments and other enforcement agencies to avoid multiple penalties for the same conduct.

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Tuesday
Apr242018

Firestone and Butenko: A Russian ‘Pilot Program’? 

Russian President Putin recently submitted a new anti-corruption bill to the Russian parliament.

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Tuesday
Apr032018

Peter Leasure: Predicting the benefits of voluntary disclosure with statistical analysis 

Studies that use statistical analysis to examine various FCPA outcomes are becoming more common. In one such paper entitled “Punishing the Penitent: Disproportionate Fines in Recent FCPA Enforcements and Suggested Improvements,” the author attempted to determine whether companies who voluntarily disclosed FCPA transgressions received a benefit in their fine calculation.

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Friday
Dec222017

DOJ gives compliance chiefs powerful new ally

The DOJ's FCPA Pilot Program -- giving companies declinations or reduced penalties if they self disclose, cooperate, and disgorge profits -- has now been enshrined in the U.S. Attorneys' Manual. It's a permanent guideline for prosecutors.

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Wednesday
Dec202017

Andy Spalding: But what can I do before a violation occurs?

By almost any measure, the new FCPA enforcement policy is an important and positive development. Tom Fox, Bill Steinman, George Terwilliger, and others both here and beyond have noted as much, and I rise in concurrence.

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Thursday
Dec142017

Lankford and Hussain: New DOJ enforcement policy takes aim at messaging apps

FCPA investigators routinely face obstacles to gathering data from non-company email and messaging apps. In particular, such communications are often not stored on company devices, and where files exist, they may be encrypted or otherwise difficult to open.  

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Friday
Dec012017

Bill Steinman: What's new about the DOJ's new FCPA corporate enforcement policy?

FCPA practitioners welcomed Rod Rosenstein’s announcement that the Department of Justice has made the FCPA Pilot Program permanent, and incorporated it into the U.S. Attorneys’ Manual. In the words of one of my colleagues, the audience “noticeably lightened up” at the Deputy AG’s news. 

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Wednesday
Nov292017

Bloomberg: DOJ making Pilot Program permanent

The DOJ's Rod RosensteinTom Schoenberg of Bloomberg reported this morning that the DOJ will convert the Pilot Program to a permanent guideline to encourage companies to self-report possible violations of the FCPA in return for leniency.

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Wednesday
Sep062017

Andy Spalding: How could we make the Pilot Program even better?

The fall is upon us, the academic year has begun, and the season is right for reflecting on all that is good and all that could be better. In the FCPA space, among the biggest stories of the last year has been the Pilot Program -- an experimental enforcement policy first announced in April 2016.

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Wednesday
Jul122017

TI-Canada recommends a deferred prosecution agreement scheme (with conditions)

A report released Wednesday by Transparency International Canada recommends the government consider adopting legislation to create a deferred prosecution agreement scheme as a way to increase transparency and promote compliance.

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Tuesday
Apr182017

DOJ’s McFadden: ‘We remain committed to enforcing the FCPA’

At this year's Anti-Corruption, Export Controls & Sanctions Summit in Washington, DC, the DOJ's Trevor McFadden talked Tuesday about the FCPA.

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