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FCPA Blog Daily News

Entries in Declinations (55)

Monday
Apr032017

FCPA enforcement report for Q1 2017

During the first calendar quarter, there were six corporate FCPA enforcement actions and one individual resolution.

Click to read more ...

Friday
Mar102017

DOJ will keep Pilot Program after April expiry during evaluation

A DOJ official said Friday the Pilot Program won't expire on April 5 but will continue while the agency evaluates how the program has worked and whether it should be extended or changed.

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Thursday
Mar022017

Crawford & Company reports SEC declination

Claims management company Crawford & Company said in its annual report that the Securities and Exchange Commission has finished its FCPA investigation and won't bring an enforcement action against the company.

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Monday
Feb202017

Question: Are there ever FCPA prosecutions for small bribes?

A reader asked if there have been any FCPA cases involving small bribes -- say under $1 million. The answer is: Yes, lots of them.

Click to read more ...

Tuesday
Jan032017

The 2016 FCPA Enforcement Index

Last year 27 companies paid about $2.48 billion to resolve FCPA cases. It was the biggest enforcement year in FCPA history. Both the number of enforcement actions and the overall amounts paid to resolve them were records.

Click to read more ...

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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Wednesday
Nov302016

Daniel Patrick Wendt: So how does the DOJ calculate disgorgement?

In the prior post I talked about how, after nearly 40 years of FCPA history, the DOJ first used disgorgement as a remedy, including it this year in two declinations under the Pilot Program.

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Monday
Nov282016

Daniel Patrick Wendt: Are those DOJ disgorgements really disgorgement?

This year the DOJ required disgorgement of ill-gotten gains as a predicate for preferential treatment under the new FCPA enforcement Pilot Program, regardless of whether the participating company was publicly or privately owned. 

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Wednesday
Nov232016

JPMorgan lands on the FCPA Top Ten Disgorgement List

Last week's $264 million enforcement action against JPMorgan Chase included disgorgement to the SEC of $130.5 million -- the seventh biggest FCPA disgorgement of all time.

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Saturday
Oct292016

Fox and Rosen: What went down in New York City

In their latest podcast, Tom Fox and Jay Rosen talk about Wednesday's FCPA Blog NYC Conference.

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Wednesday
Oct192016

Lennox International discloses alleged $425 (no zeroes) Russia bribe

Texas-based Lennox International Inc. said in a securities filing Monday that it self reported to the SEC and DOJ an alleged payment of $475 to a Russian customs broker or official.

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Friday
Sep302016

DOJ breaks new ground with two ‘declinations with disgorgement’

The Justice Department released letters Thursday under the DOJ's Pilot Program to two Texas companies that won't be prosecuted for violating the FCPA but will each have to disgorge all profits they made from the bribery.

Click to read more ...