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FCPA Blog Daily News

Entries in Pilot Progam (14)

Tuesday
Apr182017

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.

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Tuesday
Jan102017

Is Jay Clayton another Andrew Weissmann? Let's hope so

President Elect Trump’s pick to lead the SEC is Jay Clayton. He wrote in a 2011 NYC Bar Association paper about the FCPA. The paper addressed the “lasting harm to the competitiveness of U.S. regulated companies” due to the “current anti-bribery regime.”

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Monday
Dec192016

Rebecca Gantt: Looking for clues about the future of the Pilot Program

Last April, the DOJ's Criminal Division launched the one-year Pilot Program. The remaining four months of the Pilot Program promise to provide valuable information on several fronts.

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Tuesday
Dec062016

Donna Boehme: CCOs are voting with their feet, and that's good

I know that the compliance professionals in my networks understand, now more than ever, that choices have consequences, as discussed here

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Wednesday
Nov302016

Daniel Patrick Wendt: So how does the DOJ calculate disgorgement?

In the prior post I talked about how, after nearly 40 years of FCPA history, the DOJ first used disgorgement as a remedy, including it this year in two declinations under the Pilot Program.

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Monday
Nov282016

Daniel Patrick Wendt: Are those DOJ disgorgements really disgorgement?

This year the DOJ required disgorgement of ill-gotten gains as a predicate for preferential treatment under the new FCPA enforcement Pilot Program, regardless of whether the participating company was publicly or privately owned. 

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Wednesday
Nov232016

JPMorgan lands on the FCPA Top Ten Disgorgement List

Last week's $264 million enforcement action against JPMorgan Chase included disgorgement to the SEC of $130.5 million -- the seventh biggest FCPA disgorgement of all time.

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Friday
Nov042016

In state of the FCPA speech, Caldwell says Pilot Program is working

DOJ criminal division chief Leslie Caldwell used a wide-ranging talk Thursday at George Washington University Law School to defend the six-month old Pilot Program and to describe the Justice Department's FCPA enforcement efforts and the current state of corporate compliance.

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Saturday
Oct292016

Fox and Rosen: What went down in New York City

In their latest podcast, Tom Fox and Jay Rosen talk about Wednesday's FCPA Blog NYC Conference.

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Friday
Oct282016

Lanny Breuer: Pilot Program falls short

The DOJ's Pilot Program to encourage companies to self report bribery and cooperate with prosecutors doesn't fix some problems with FCPA investigations and enforcement actions, Lanny Breuer said Wednesday.

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Wednesday
Oct192016

Lennox International discloses alleged $425 (no zeroes) Russia bribe

Texas-based Lennox International Inc. said in a securities filing Monday that it self reported to the SEC and DOJ an alleged payment of $475 to a Russian customs broker or official.

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Wednesday
Oct122016

Matt Reeder: Do Pilot Program disclosures raise risks of carbon copy prosecutions?

In April the DOJ launched its FCPA self-reporting Pilot Program for the purpose of increasing the number of companies voluntarily disclosing FCPA violations. The program was designed to achieve this goal with a carrot and stick approach.

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