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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
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

A Rare (Or Medium-Rare) Opportunity

Review Procedure Release No. 81-02 from December 11, 1981 may be a Cold War relic, but it’s still relevant to the FCPA. It answers the question: How do you introduce new products to potential government customers in foreign countries without violating the Foreign Corrupt Practices Act?… Continue Reading

Kay Day At The Court’s Conference

I have a question for anyone on the FCPA blog, a reader wrote ten days ago: Are there any known cases where an individual was prosecuted allegedly for bribing a foreign official where the “donor” did not ask for anything from the foreign official and where he received nothing?Continue Reading

Dear FCPA Blog . . . .

What a week for mail! Just this morning, for example, we learned we’d won the Spanish Lottery. The €850,000 prize that’s waiting for us would put a lot of gas in the tank, even at today’s prices.… Continue Reading

Rocket Scientist Arrested Under FCPA

The U.S. Department of Justice reported the arrest in Virginia on Wednesday of a physicist accused of bribing Chinese government officials in exchange for contracts to supply space-launch technology that he illegally exported to China.… Continue Reading

French Citizen Jailed For FCPA Offenses

Former Alcatel executive Christian Sapsizian, 62, has been sentenced to 30 months in prison, three years of supervised release, and forfeiture of $261,500 for bribing employees of the state-owned telecommunications authority in Costa Rica.… Continue Reading

The Supremes And The FCPA

Questions about ambiguity in the Foreign Corrupt Practices Act have been around since its inception. See, for example, our post Looking Again At U.S. v. Kay (November 7, 2007). The Supreme Court will answer those questions soon, either by granting review of Kay and deciding what “obtaining or retaining business” means, or by refusing to take the case and allowing the government to continue its “expansive enforcement” of the law.… Continue Reading

The Tally, Part 2

Following yesterday’s post, several readers suggested that we mention any other FCPA-related cases, appeals, sentencings and enforcement actions during the past year involving individuals. It’s a good idea, and our thanks go out to Marc and our other correspondents.… Continue Reading

What’s The Tally?

The Justice Department says it plans to prosecute more individuals under the Foreign Corrupt Practices Act — and send them to jail. We looked through our posts to see how men and women fared over the past year.… Continue Reading

The FCPA Isn’t Fun And Games

Mark Mendelsohn — the Justice Department official responsible for criminal prosecutions under the Foreign Corrupt Practices Act — has left no doubt that the government is targeting individuals. Here’s what he told an audience at an American Bar Association panel discussion in Washington, D.C.… Continue Reading

No Foreign Official, No FCPA Offense

CW (who knows a lot about the Foreign Corrupt Practices Act) asked a great question. Can a payment directly to a foreign government intended to influence decisions in favor of the donor violate the FCPA?… Continue Reading

Oiling The Wheels Of Government

We somehow remained cheerful this week, despite the gloomy news from Fenway and Tom Brady’s knee injury. Knees, by the way, seem oddly under-designed, unless their real purpose is to keep us humble.… Continue Reading

Intent On Complying

The shocking news last week about Jack Stanley’s guilty plea teaches again that not all FCPA violations can be prevented. No compliance program or compliance training would have kept Mr. Stanley on the right side of the law.… Continue Reading