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 Enforcement Policy (76)


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?”

Click to read more ...


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.

Click to read more ...


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.

Click to read more ...


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.

Click to read more ...


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.

Click to read more ...


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.  

Click to read more ...


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.

Click to read more ...


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.

Click to read more ...


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.

Click to read more ...


Alexandra Wrage: Compliance and Enforcement Trends from the 2017 TRACE Forum

Last week, TRACE held its 13th Forum at the St. Regis Hotel in Washington, D.C. Over 100 member companies contributed to a lively and extended exchange of best practices across the two-day event.

Click to read more ...


Donna Boehme: Chief compliance officers (and the DOJ) want accountability and discipline

CCOs know that accountability and discipline are difficult and perilous areas to embed in their programs for a number of reasons.

Click to read more ...


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.

Click to read more ...