For years now, a certain reader has been stitching together for us enforcement topics in ways we hadn’t thought of.
This time our friend — who’s a top compliance professional and wants to remain anonymous — connects the dots from a few recent headlines.… Continue Reading
Will disclosures by Wikileaks ever lead to prosecutions under the Foreign Corrupt Practices Act?
Maybe. The whistleblower site said this week that among the classified U.S. diplomatic cables it plans to publish soon will be some alleging corruption in foreign governments.… Continue Reading
By Jeffrey M. Kaplan
Since 1991 –- even prior to the Sentencing Guidelines going into effect -– Justice Department officials have said corporate charging decisions should be based in part on how effective a corporation’s compliance program was at the time of the offense in question.… Continue Reading
Creation has given up many of its deepest secrets. But how sentencing decisions are made in FCPA-related cases isn’t one of them.
To prove that, listen to the following exchange. It occurred in July this year when Juan Diaz, a Miami businessman, appeared in federal court to learn his fate.… Continue Reading