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Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Richard L. Cassin Editor at Large

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

FCPA Blog Daily News

Entries in Cooperation (48)

Wednesday
Aug072019

SFO issues guidance for corporate cooperation

SFO Director Lisa OsofskyThe UK Serious Fraud Office published a five-page memo Tuesday that tells companies the steps they should take if they decide to cooperate with the agency in an investigation.

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Thursday
Mar072019

Practice Alert: CFTC will investigate and prosecute FCPA violations

The Commodity Futures Trading Commission (CFTC) said Wednesday it will work alongside of the DOJ and SEC to investigate foreign bribery and prosecute overseas corruption offenses.

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Friday
Jun082018

Hating on the FCPA won't make it go away

The lawyer from Europe was quick to tell us what she thinks of the FCPA. "It's really just a weapon against non-U.S. companies," she said. "Very bad."

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Thursday
May172018

Covington and Hantman: New DOJ policy against piling on has rewards, with strings attached

A common refrain in the white collar bar is that American government agencies don’t often get along and play well together. This can result in challenging issues for companies doing business in the United States that have run afoul of the law.

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Thursday
May102018

DOJ rolls out new policy against ‘piling on’ 

Deputy Attorney General Rod Rosenstein announced a new policy Wednesday that encourages coordination among DOJ departments and other enforcement agencies to avoid multiple penalties for the same conduct.

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Tuesday
Apr242018

Firestone and Butenko: A Russian ‘Pilot Program’? 

Russian President Putin recently submitted a new anti-corruption bill to the Russian parliament.

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Tuesday
Apr032018

Peter Leasure: Predicting the benefits of voluntary disclosure with statistical analysis 

Studies that use statistical analysis to examine various FCPA outcomes are becoming more common. In one such paper entitled “Punishing the Penitent: Disproportionate Fines in Recent FCPA Enforcements and Suggested Improvements,” the author attempted to determine whether companies who voluntarily disclosed FCPA transgressions received a benefit in their fine calculation.

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Friday
Dec222017

DOJ gives compliance chiefs powerful new ally

The DOJ's FCPA Pilot Program -- giving companies declinations or reduced penalties if they self disclose, cooperate, and disgorge profits -- has now been enshrined in the U.S. Attorneys' Manual. It's a permanent guideline for prosecutors.

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Wednesday
Dec202017

Andy Spalding: But what can I do before a violation occurs?

By almost any measure, the new FCPA enforcement policy is an important and positive development. Tom Fox, Bill Steinman, George Terwilliger, and others both here and beyond have noted as much, and I rise in concurrence.

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Thursday
Dec142017

Lankford and Hussain: New DOJ enforcement policy takes aim at messaging apps

FCPA investigators routinely face obstacles to gathering data from non-company email and messaging apps. In particular, such communications are often not stored on company devices, and where files exist, they may be encrypted or otherwise difficult to open.  

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Friday
Dec012017

Bill Steinman: What's new about the DOJ's new FCPA corporate enforcement policy?

FCPA practitioners welcomed Rod Rosenstein’s announcement that the Department of Justice has made the FCPA Pilot Program permanent, and incorporated it into the U.S. Attorneys’ Manual. In the words of one of my colleagues, the audience “noticeably lightened up” at the Deputy AG’s news. 

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Wednesday
Nov292017

Bloomberg: DOJ making Pilot Program permanent

The DOJ's Rod RosensteinTom Schoenberg of Bloomberg reported this morning that the DOJ will convert the Pilot Program to a permanent guideline to encourage companies to self-report possible violations of the FCPA in return for leniency.

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