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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 (36)

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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Monday
Dec192016

Rebecca Gantt: Looking for clues about the future of the Pilot Program

Last April, the DOJ's Criminal Division launched the one-year Pilot Program. The remaining four months of the Pilot Program promise to provide valuable information on several fronts.

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Friday
Oct282016

Lanny Breuer: Pilot Program falls short

The DOJ's Pilot Program to encourage companies to self report bribery and cooperate with prosecutors doesn't fix some problems with FCPA investigations and enforcement actions, Lanny Breuer said Wednesday.

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Wednesday
Oct122016

Matt Reeder: Do Pilot Program disclosures raise risks of carbon copy prosecutions?

In April the DOJ launched its FCPA self-reporting Pilot Program for the purpose of increasing the number of companies voluntarily disclosing FCPA violations. The program was designed to achieve this goal with a carrot and stick approach.

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Tuesday
Sep132016

Jorge and Kenney: Argentina considers bill to enable corporate bribery prosecutions

Argentina's National Congress will soon consider a bill that would finally enable prosecutors to bring criminal charges against corporations that engage in bribery and other corrupt acts.

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Monday
Aug152016

What's behind Key Energy's ‘disgorgement-only’ settlement?

Key Energy Services, Inc. resolved an SEC enforcement action Friday by disgorging $5 million but not paying any other penalties.

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Tuesday
Jul122016

Johnson Controls pays SEC $14 million to settle China bribe case, receives DOJ Pilot Program declination

Johnson Controls Inc. agreed Monday to pay $14 million to settle SEC charges that it violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act.

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Thursday
Jun232016

The Analogic Settlement: What's behind the issue of cooperation credit?

As reported by the FCPA Blog Tuesday, the SEC and DOJ entered into parallel resolutions with Analogic Corporation and Analogic's wholly-owned Danish subsidiary BK Medical ApS in connection with violations of the books and records and accounting controls provisions of the FCPA.

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Wednesday
Jun082016

Here's what a Pilot Program declination letter looks like

After Nortek and Akamai resolved FCPA enforcement actions with the SEC Tuesday with non-prosecution agreements requiring cooperation and disgorgement, both companies released declination letters issued under the DOJ's new Pilot Program.

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Wednesday
May112016

Yates Speaks: Prosecuting individuals is really hard, so companies need to come clean

Deputy Attorney General Sally Q. Yates spoke Tuesday to the New York City Bar Association White Collar Crime Conference. Her topic? That's right. The Yates Memo, more formally known as the DOJ's Individual Accountability Policy.

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