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Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Harry Cassin Managing 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 Enforcement Policy (84)

Wednesday
Sep192018

Bonifassi and Chatelin: France has DPAs, but needs more guidance

The French government enacted the law commonly known as Loi Sapin II, paving the way for out-of-court settlements, on December 9, 2016. And the French Ministry of Justice issued regulatory guidelines on the subject on January 31 this year.

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Wednesday
Jul252018

Jesse Van Genugten: Foreign companies should beware of lopsided FCPA enforcement

In a novel, even if rather obscure manner, the Trump Administration has found a new way to put America first.

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Wednesday
Jul112018

Martin Kenney on UK enforcement: Repay what you stole, or stay in prison

It is refreshing that a convicted fraudster, who is already serving a custodial sentence for his original crime, has had his sentence increased due to his failure to repay millions of dollars to his victims.

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Thursday
Jun282018

Bart M. Schwartz: Why independent compliance reviews are ‘forward thinking’ 

At the heart of any prospective self-disclosure to the DOJ is a robust internal compliance review program. Companies, no matter how big or small, should be looking to do two things: evaluate past practices and ensure ongoing compliance.

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Monday
Jun112018

Bill Steinman: The FCPA is not dead redux

Last week the Department of Justice reminded us that the FCPA remains a force to be reckoned with. And for the second time in as many years, I’ve taken to my keyboard to remind the world that, despite so many hopes and predictions, FCPA enforcement is not dead.

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Wednesday
May232018

Brackett and Earley: DOJ enforcement policy announcements provide promising guidance

In a series of key policy announcements between November 2017 and May 2018, the Department of Justice has demonstrated an increasingly coherent perspective on how it will handle key aspects of white collar criminal enforcement.

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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
Mar292018

Eric Carlson: Expect more anti-corruption enforcement in China

China’s biggest government reorganization in a generation, coinciding with rapidly escalating U.S.-China trade tensions, will impact many aspects of doing business in China, including an uptick in anti-corruption enforcement.

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Thursday
Mar222018

Robert Clark: U.S. enforcement is down, but international enforcement is up

The release of TRACE’s Global Enforcement Report 2017 (GER) gives us a chance to reflect on large-scale trends in anti-bribery enforcement.

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Monday
Mar122018

Eric Carlson: In China investigations, messaging platforms can be a goldmine or a landmine

Anyone who has spent much time in China or dealt with investigations in China has probably heard of WeChat, a social media application. WeChat has over 900 million daily users, making it far and away the most ubiquitous social media platform in China. 

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Tuesday
Feb202018

Tillipman and Block: Should criminal settlements be available to corporate recidivists?

Few corporations are willing to risk the extensive legal costs, reputational damage, and potentially devastating collateral consequences of a trial. Thus, unsurprisingly, corporate settlements have proliferated in recent years, becoming a staple of the U.S. criminal justice system.

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Monday
Jan222018

Are there ‘aggravating circumstances’ in all FCPA cases?

The FCPA guidance that became part of the U.S. Attorneys’ Manual in November creates a presumption of declination if companies do four things -- voluntarily self-disclose, fully cooperate, properly remediate, and disgorge their profits. But there's an important exception.

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