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Editors

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

The Thing About Foreign Officials

Some of our favorite websites are asking whether employees of government-linked companies are really “foreign officials” under the FCPA. The DOJ has always insisted they are. But that interpretation has never been tested in court, allowing proponents to say the DOJ has taken improper liberties with the statute’s text.… Continue Reading

Risk-Based Compliance: First Steps

Scott Moritz: Risk-based compliance can work, even for the world’s biggest companies. By Scott Moritz

Who are your highest-risk third parties and what are you doing about them? Most FCPA enforcement actions involve payments through agents and other intermediaries.… Continue Reading

Headwinds In London

SFO Director Richard Alderman: Good job, don’t do it again. A senior Crown Court judge on Friday warned the head of Britain’s Serious Fraud Office (SFO) that he doesn’t have the legal authority to settle corruption prosecutions with plea bargains.… Continue Reading

Not All Corruption Is Created Equal

In the latest edition of Foreign Policy magazine, Ray Fisman, a professor at the Columbia Business School, has a short commentary with an unusual slant: Corruption that’s predictable and stable is easy for investors to deal with and may not do that much harm to local economies.… Continue Reading

Freeh Named Daimler Monitor

Former FBI director Louis Freeh will act as compliance monitor to German vehicle-maker Daimler AG, which is expected to obtain court approval on April 1st for its settlement with the Justice Department of two FCPA-related charges.… Continue Reading

Where To Look

Be sure to check out Shearman & Sterling’s searchable data base here. It’s utterly amazing and free to use. Searches return cases, pleadings, dollar amounts, countries involved, dispositions, and related actions.… Continue Reading

Daimler Deal Reported

The New York Times’s DealBook says in a post today that “Daimler has agreed to pay about $185 million in fines, and two of its subsidiaries will plead guilty to bribing foreign government officials, to settle a multiyear corruption investigation.”… Continue Reading

Code Named Ruthenium

The U.K.’s Serious Fraud Office today reported in dramatic fashion the arrest of three top executives of French industrial giant Alstom’s British unit. They’re suspected of paying bribes overseas to win contracts.… Continue Reading

Daimler Charged For Bribery [Updated]

Germany’s Daimler AG has been charged in a criminal information with Foreign Corrupt Practices Act-related violations involving “at least 22 countries over almost a decade.” China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia, Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, and Vietnam are among the countries mentioned.… Continue Reading

Speaking Freely

The Miller Center of Public Affairs at the University of VirginiaThe Miller Center of Public Affairs [at the University of Virginia] has a long tradition of luring influential people to speak to engaged citizens, but this genteel practice degenerated on Friday, March 19, at an appearance by the lawyer who wrote the infamous “torture memos” that the Bush Administration used to justify waterboarding terrorist suspects.Continue Reading