Before the Siemens case and the birth of the modern era of FCPA enforcement, there were the ten elements of an effective compliance program. They came from the U.S. federal sentencing guidelines applicable to corporate defendants.
Entries in Federal Sentencing Guidelines (72)
A status conference in U.S. v. Weissman before Judge Barbara S. Jones in New York City has been scheduled for January 3.
The former director of worldwide sales for Control Components Inc. was sentenced Thursday to 13 months home confinement and fined $20,000 for bribing Chinese officials.
The one-time middleman for KBR and its partners stood before Judge Keith P. Ellison in a Houston courtroom in February. Jeffrey Tesler faced up to ten years in prison.
The DOJ said in a court filing last week that it would be satisfied with home confinement instead of prison for Paul Cosgrove because of his serous health problems.
The Tulsa, Oklahoma company and affiliates bribed 'employees of airlines created, controlled and exclusively owned by the People’s Republic of China in order to secure contracts' from those airlines, the DOJ said.
Earlier this week, when the DOJ and SEC charged Garth Peterson with FCPA violations, both agencies publicly announced that they had declined to prosecute or charge his employer, Morgan Stanley, because of its strong compliance program.
When BizJet paid $11.8 million this week to settle an FCPA conspiracy count, it received a huge discount from the DOJ.
A reader of the FCPA Blog asked yesterday about apparent disparities in sentences between 'white collar' and 'blue collar' FCPA defendants, as he called them.
A reader sees differences in the “white collar” v. “blue collar” FCPA sentences. He defines white collar as executives at very large multinationals. They seem to get little or very light sentences.