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

Aarti Maharaj Contributing Editor

FCPA Blog Daily News

Entries in Yates Memo (31)


Bill Waite: Progress, yes. But victory against corruption remains uncertain

In the prior post and this one, I'm looking at big events and trends since the FCPA Blog started publishing 11 years ago, and their impact on corruption, enforcement, and compliance.

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Brackett and Earley: DOJ enforcement policy announcements provide promising guidance

In a series of key policy announcements between November 2017 and May 2018, the Department of Justice has demonstrated an increasingly coherent perspective on how it will handle key aspects of white collar criminal enforcement.

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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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Tillipman and Block: Should criminal settlements be available to corporate recidivists?

Few corporations are willing to risk the extensive legal costs, reputational damage, and potentially devastating collateral consequences of a trial. Thus, unsurprisingly, corporate settlements have proliferated in recent years, becoming a staple of the U.S. criminal justice system.

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What does Paul Pelletier really think about DPAs, individual prosecutions, and the DOJ?

Pepper Hamilton's Paul PelletierThe Chickenshit Club: Why the Justice Department Fails to Prosecute Executives by Jesse Eisinger talks about what has brought us to present-day enforcement challenges and controversies.

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U.S. commitment to enforcing the FCPA – A discussion with Philip Urofsky

Last week I spoke with Philip Urofsky, a partner at Shearman and Sterling, and a former federal prosecutor, responsible for investigating and advising on matters involving potential violations of the Foreign Corrupt Practices Act.

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Andy Spalding: How could we make the Pilot Program even better?

The fall is upon us, the academic year has begun, and the season is right for reflecting on all that is good and all that could be better. In the FCPA space, among the biggest stories of the last year has been the Pilot Program -- an experimental enforcement policy first announced in April 2016.

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Fahira Brodlija: The case for an FCPA compliance defense

The U.S. legal system doesn't provide for an FCPA compliance defense, which would relieve a company of liability for FCPA violations if it can prove that it created and maintained an effective FCPA compliance program at the time the violation occurred.

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FBI Special Agent Adam Lee on FCPA probes: ‘We use all of the techniques available to us’

I spoke last Thursday with Adam S. Lee, the Special Agent in charge of the U.S. Federal Bureau of Investigation's Richmond Division.

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Richard Bistrong: I wanted to go home, the judge wanted me in jail

A few weeks ago, I read about an “exasperated federal judge” at the sentencing of Samuel Mebiame, the 43-year-old son of the former prime minister of Gabon, who was an intermediary for Och-Ziff. 

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Resource Alert: How to do business during a corruption investigation

Shearman & Sterling has published a client alert a lot of us need these days -- “Transacting Business During a Corruption Investigation.”

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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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