Get ready for even more FCPA enforcement against individuals. The DOJ’s Mark Mendelsohn was quoted this week by Reuters as saying:
“If you look at who we’re prosecuting, we’re prosecuting mid-level to senior level corporate officers and employees, CEOs, CFOs, heads of international sales. My point is these are people with significant positions in companies.”
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Innospec’s docs. Thanks to the kindness of a reader, the criminal information, sentencing memo, and plea agreement can now be downloaded from our post here.
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For the record. Andy Spalding, whose provocative comments appear in this space from time to time, has never said graft is good. Our over-zealous headline writers came up with that silly phrase.
Andy himself says: “I certainly don’t believe that ‘graft is good’ . . . I do believe, though, that our efforts to reduce bribery can, quite unintentionally, sometimes produce bad results. But fortunately, we need not choose between enforcing the FCPA or not. Rather, we should develop an approach to enforcement that is more sensitive to the reality of collateral damage in economically desperate countries, one that punishes bribery without punishing the citizens, for example, of Haiti.”
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What time is it there? Expanding cooperation between the DOJ and the U.K.’s Serious Fraud Office is one of the year’s most important FCPA enforcement trends. How’s it working? We don’t really know. But it brought to mind this clip from Extras.