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 Declinations (72)


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. 

Click to read more ...


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.

Click to read more ...


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.

Click to read more ...


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.

Click to read more ...


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 ...


Cisco investigation ends with DOJ, SEC declinations

Networking giant Cisco Systems Inc. said in its annual report Thursday that following an investigation into operations in Russia and some CIS countries, the DOJ and SEC won't bring FCPA enforcement actions.

Click to read more ...


FCPA enforcement report for Q2 2016

During the second calendar quarter, there were four corporate FCPA enforcement actions and eight individual resolutions (seven related to Direct Access Partners). There were also three guilty pleas by individuals.

Click to read more ...


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.

Click to read more ...


Akamai, Nortek settle China bribe cases with SEC non-prosecution agreements

The Securities and Exchange Commission Tuesday announced non-prosecution agreements (NPAs) with two unrelated companies for bribes foreign subsidiaries paid to Chinese officials.

Click to read more ...


DOJ declination for Key Energy, SEC settlement reached ‘in principle’

Key Energy Services Inc. said Thursday the Justice Department informed the company that it has closed its FCPA investigation and won't bring an enforcement action.

Click to read more ...


DOJ launches FCPA self-reporting pilot program with new guidance

Assistant Attorney General Leslie R. CaldwellAssistant Attorney General Leslie Caldwell announced a one-year pilot program Tuesday intended to encourage companies to self report FCPA offenses and cooperate with the Justice Department.

Click to read more ...


SBM Offshore: DOJ re-opens overseas bribe probe

SBM Offshore confirmed Wednesday that the U.S. Department of Justice has re-opened its investigation into the alleged bribery of government officials in Angola, Brazil, and Equatorial Guinea between 2007 and 2011.

Click to read more ...