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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 (67)

Tuesday
Jun282016

Paper: FCPA enforcement actions don't hurt profitability

Companies are penalized hundreds of millions of dollars for corruption. But are the penalties high compared to what the companies go on to earn?

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Wednesday
May182016

Joseph Spinelli: Yes, the Yates Memo is a watershed event

Career prosecutor and current Deputy AG Sally Yates authored one the most important DOJ policy papers in decades -- the Yates Memo, also known as the DOJ's Individual Accountability Policy.

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Wednesday
Apr062016

Bill Steinman was right. FCPA enforcement is alive and well

In early January, Washington lawyer Bill Steinman said in a post for the FCPA Blog that 2016 was likely to be a big year for FCPA enforcement. His words were prophetic.

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Monday
Feb152016

Joe Murphy: Big Brothers penalty shows our dysfunctional legal system

OK, here is the starting point. Someone breaks the law and they need to be punished. Sounds good. Someone misuses government money and is penalized. Still sounds good. 

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Monday
Feb012016

Paul Pelletier: Sporadic enforcement isn't effective enforcement

At a recent ubiquitous FCPA conference, Assistant Attorney General Leslie Caldwell noted that even more resources would be added to the Fraud Section’s FCPA Unit, increasing the number of prosecutors by 50% from 20 to 30 trial attorneys, making this specialty unit larger than the entire white collar sections of most United States Attorneys’ Offices nationwide.

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Monday
Jan112016

Bill Steinman: Reports of the FCPA’s demise are greatly exaggerated (and just plain wrong)

This time of year, FCPA prognosticators abound.  Just as the arrival of a New Year is heralded by the popping of champagne corks, January brings with it much gazing into our FCPA crystal balls. Looking back over the prior year, we do our best to offer insight into what enforcement trends the New Year will bring.

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Monday
Oct262015

Joseph Spinelli: FCPA enforcement takes aim at financial services 

This summer the SEC charged BNY Mellon with violating the FCPA by providing highly sought-after student internships to family members of foreign government officials who were directly affiliated with a Middle Eastern sovereign wealth fund. The enforcement action is a clear harbinger of what's to come.

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Tuesday
Oct062015

Alex Brackett: SEC ‘broken windows’ enforcement policy is showing FCPA results

In October 2013, SEC Chairwoman Mary Jo White announced a broken windows enforcement policy to “pursue even the smallest infractions” of U.S. securities laws, including the FCPA, as a means of deterrence. 

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Wednesday
Sep162015

Are settlements a deterrent or a dodge?

The DOJ has unveiled new guidance to federal prosecutors about bringing criminal cases against individuals in instances of corporate wrongdoing.

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Monday
Sep142015

Richard Bistrong: Turn off the movie and read the Yates Memo

When I was asked last week during a TV interview if I once believed I could do wrong with impunity, I responded, “I never thought about getting caught.” Now, almost ten years after my last criminal act, comes the Yates Memo.

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Friday
Jan232015

Paper: The FCPA is a new ‘international business tax’ on non-U.S. companies

After conducting statistical analysis on Foreign Corrupt Practices Act penalties, it's clear that foreign firms are paying nearly four times higher FCPA penalties as domestic U.S. firms. 

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Wednesday
Oct292014

In defense of the Caldwell Doctrine

Image courtesy of C-Span via YoutubeAs the FCPA Blog reported last week, DOJ criminal division chief Leslie Caldwell recently gave an important talk at Duke Law School in which she laid out her vision of the Foreign Corrupt Practices Act. Her vision is compelling, and important, in so many ways. I rise in defense of one of them.

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