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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

In FCPA Sentencings, What’s A ‘Benefit Received’?

By Dr. Patrick Conroy and Dr. Graeme Hunter

Fines and disgorgements for FCPA offenses are based on the “benefit received” from a bribe.

With those penalties now reaching hundreds of millions of dollars and with increasing enforcement, it’s important to understand what effect a bribe had on profits, and to carefully establish what the but-for profits would have been without the bribe.… Continue Reading