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Entries in Miscellaneous Receipts Act (5)

Friday
Feb102017

What will $30 million of the Rolls-Royce fine be used for?

Last month Rolls-Royce agreed in a deferred prosecution agreement with the DOJ to pay a fine of nearly $170 million for FCPA  violations. What makes the Rolls-Royce DPA unique is that $30 million of the fine went to the Consumer Financial Fraud Fund (CFFF).

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Wednesday
Apr292015

The BOTA Foundation explained (Part Twelve, conclusion): Future BOTAs and the FCPA

Aaron Bornstein wrote in the prior post of the potential to use recovered bribe proceeds or stolen assets to fund BOTA-inspired programs in developing countries. That possibility is real, and important.  But recognize that the majority of FCPA settlements do not involve traceable and recoverable assets -- the money is typically long gone. So if we are to create more BOTAs, we must fund them with the money that is available in your more typical FCPA settlement.

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Thursday
Oct022014

The much misunderstood Miscellaneous Receipts Act (Part 4, conclusion)

We provided a number of examples in the prior post when the DOJ funded community service projects with settlement money while fully complying with the MRA. Indeed, these projects have become more common, not less, in recent years.

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Tuesday
Sep302014

The much misunderstood Miscellaneous Receipts Act (Part 2)

Image courtesy of the U.S. governmentWe explained in the prior post that the MRA is a seemingly absolute bar to using settlement money to fund community programs (or anything else, for that matter). After all, the statute is unequivocal: any government official “receiving money for the Government from any source shall deposit that money with the Treasury.”  31 U.S.  § 3302(b).

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Monday
Sep292014

The much misunderstood Miscellaneous Receipts Act (Part 1)

We’ve heard it so many times:  the Miscellaneous Receipts Act prohibits federal enforcement agencies from doing anything with settlement money other than depositing 100% of it in the U.S. Treasury.

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