Skip to content


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

What Sentence Is Fair For Naaman?

When Ousama Naaman is sentenced — now scheduled for December 22 at 10:30 AM before Judge Ellen S. Huvelle in federal court in the District of Columbia — prosecutors will ask for a seven and half year prison term.… Continue Reading

Aon Pays $16.2 Million In Settlement

Aon Corporation, one of the biggest insurance brokerage firms in the world, agreed today to resolve FCPA charges with the DOJ and SEC.

It will pay a $1.76 million criminal penalty to the DOJ and $14.5 million in disgorgement and prejudgment interest to the SEC.… Continue Reading

At The SFO, Green Shoots

The new head of the Serious Fraud Office has just been announced. David Green CB Q.C (left) is an interesting man. He started his career with three years in defence intelligence at the Ministry of Defence, studied for the Bar part time before joining one of the foremost criminal sets of Barristers in the country. … Continue Reading

Fox’s Top Ten For 2011, Corporate Division

As December is a time for reflection on the past twelve months, I have been considering the FCPA Enforcement Action year.

I submit for your consideration my Top 10 FCPA Enforcement Actions for 2011 in the Corporate Division.… Continue Reading

Frederic Bourke And The Four Bad Facts

The Second Circuit Court of Appeals recently released its long-awaited opinion in the appeal of hand-bag mogul turned FCPA defendant Frederic Bourke.

Bourke advanced a number of issues on appeal, but from an FCPA perspective none were as interesting as his contention that the trial court erred in giving a “conscious avoidance” instruction to the jury.… Continue Reading

Insuring Against Disgorgement

When companies disgorge profits to the SEC in FCPA settlements, can they claim reimbursement under their directors and officers liability insurance policies?

We’re not aware of coverage litigation in FCPA-related disgorgement cases.… Continue Reading

Updated: Bourke Conviction Upheld On Appeal

Frederic Bourke’s conviction on an FCPA conspiracy was upheld by the Second Circuit Court of Appeals.

Bourke was found guilty by a federal jury in Manhattan in July 2009 of investing in an oil privatization scheme in Azerbaijan despite knowing officials there would be bribed.… Continue Reading