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Richard L. Cassin Publisher and Editor

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Jessica Tillipman Senior Editor

Elizabeth K. Spahn Editor Emeritus

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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

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FCPA Blog Daily News

Entries in Enforcement Policy (67)

Wednesday
Oct042017

Karen E. Gray: ISO 37001 certification can help companies prepare for DOJ industry sweeps

After news broke that the U.S. Department of Justice was investigating Uber’s potential violations of the Foreign Corrupt Practices in late August, the National Law Review wrote, “In our experience, once DOJ begins learning about a particular industry in such an investigation, the investigation will expand to other players within the industry. It’s called an ‘industry sweep,’ and it’s a thing.”

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Thursday
Sep282017

Gary Giampetruzzi: Is Small Pharma next for DOJ enforcement? 

For decades, U.S. prosecutors have touted their big victories over big pharma for violations of U.S. laws prohibiting bribery in the U.S. (the federal Anti-Kickback Statute) and abroad (the FCPA). 

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Thursday
Sep282017

What does Paul Pelletier really think about DPAs, individual prosecutions, and the DOJ?

Pepper Hamilton's Paul PelletierThe Chickenshit Club: Why the Justice Department Fails to Prosecute Executives by Jesse Eisinger talks about what has brought us to present-day enforcement challenges and controversies.

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Monday
Sep252017

Andy Spalding: A plea to the DOJ -- bring back pre-existing compliance

At a recent conference, I had the good fortune of asking a former high-ranking DOJ official, “how is it that pre-existing compliance is no part of the Pilot Program’s penalty reductions and declinations?”

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Thursday
Sep142017

Andy Spalding: The Pilot Program addresses three criticisms, but raises a new one

The Pilot Program is best understood as the DOJ’s response to three distinct lines of public commentary on FCPA enforcement. The Department should be commended for responding to this commentary -- indeed, for even listening to it in the first place. And the responses have, in my view, largely been smart and fair. But it’s created a new difficulty. Fortunately, that difficulty is easily addressed.

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Wednesday
Sep132017

U.S. commitment to enforcing the FCPA – A discussion with Philip Urofsky

Last week I spoke with Philip Urofsky, a partner at Shearman and Sterling, and a former federal prosecutor, responsible for investigating and advising on matters involving potential violations of the Foreign Corrupt Practices Act.

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Thursday
Sep072017

Karen E. Woody: Declinations with disgorgement make me queasy. Here's why

As readers of the FCPA Blog are aware, the Pilot Program requires voluntary self-disclosure and cooperation with the government in order to be eligible for a declination from the DOJ.

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Thursday
Aug312017

Juan Manuel Bedoya-Palacio: Colombia enters the era of enforcement

Following a peace agreement that ended more than 50 years of civil conflict against the drug cartels and FARC (the Colombian Revolutionary Armed Forces, for its initials in Spanish), the focus now in Colombia is on exposing and prosecuting corruption.

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Monday
Aug282017

Bethany Hipp: How can compliance officers protect themselves from harm?

Recent enforcement actions suggest that regulators, both in the United States and the UK, are targeting compliance officers.  

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Thursday
Aug102017

Jampol and Aibel: DOJ targets healthcare with FCPA enforcement

The acting chief of the DOJ's Criminal Fraud Section announced a new partnership last month between the DOJ’s Healthcare Fraud Unit’s Corporate Strike Force and Foreign Corrupt Practices Act prosecutors.

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Tuesday
Apr252017

AG Sessions: ‘We will continue to strongly enforce the FCPA’

Attorney General Jeff Sessions said Monday that enforcing the Foreign Corrupt Practices Act is critical to protecting honest companies from competitors who choose to pay bribes.

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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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