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Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Harry Cassin Managing 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

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FCPA Blog Daily News

Entries in US Attorney's Manual (7)

Thursday
Jun282018

Bart M. Schwartz: Why independent compliance reviews are ‘forward thinking’ 

At the heart of any prospective self-disclosure to the DOJ is a robust internal compliance review program. Companies, no matter how big or small, should be looking to do two things: evaluate past practices and ensure ongoing compliance.

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Friday
Mar092018

Dealbreaker: ‘Wells Fargo is having its soul investigated by actual nuns’

I wish I could write a headline as great as the above banner which appeared over a piece written by Thorton McErney in Dealbreaker.

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Monday
Jan222018

Are there ‘aggravating circumstances’ in all FCPA cases?

The FCPA guidance that became part of the U.S. Attorneys’ Manual in November creates a presumption of declination if companies do four things -- voluntarily self-disclose, fully cooperate, properly remediate, and disgorge their profits. But there's an important exception.

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Monday
Dec042017

George J. Terwilliger III: Finally, A Sensible Anti-Corruption Enforcement Policy

Deputy Attorney General Rod Rosenstein’s announcement of a permanent expansion of the Department of Justice Foreign Corrupt Practices Act “Pilot Program” is good news for companies that repeatedly faced the dilemma of whether or not to investigate and disclose FCPA issues discovered internally.

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Monday
Oct272014

DOJ position on anti-trust compliance programs needs a make over

In the FCPA area we all know how important it is to have effective compliance programs. The DOJ’s Criminal Division and the SEC have emphasized that these programs need to be diligent, and not mere formalities. Moreover, we know that programs count to the enforcers, so we have a reason to listen to them. The FCPA Guidance tells us this, and declinations such as Morgan Stanley demonstrate it.

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Thursday
Oct022014

Dispatch from the SCCE Compliance & Ethics Institute (Part Five, conclusion)

The SCCE Compliance & Ethics Institute could become the focus for an annual debate within the compliance field about the critical issues ahead. In honor of the SCCE’s 10 years of supporting compliance officers, here are my top ten suggestions for next year’s SCCE agenda:

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Monday
Feb172014

Are all FCPA lawyers and compliance officers fair game for NSA spying?

Image courtesy of the Australian Signals DirectorateA document from Edward Snowden dated February 2013 showed that the Australian Signals Directorate spied on an American law firm and passed the results to the NSA, the New York Times said Saturday.

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