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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

Regarding Foreign Evidence, The Echo Of History

[The DOJ] rarely has the ability to obtain the testimony of foreign witnesses. It is difficult to obtain foreign documents. Defense lawyers should put the government to its burden of proof and not confess without a trial.

— Joel Androphy, John O’Shea’s defense lawyer, to the FCPA Blog, January 19, 2012

*     *     *

Our experience in combatting domestic political corruption, coupled with our own recent efforts to develop prosecution [sic] involving the bribery of foreign officials amply demonstrates the difficulties of gathering sufficient credible and admissible evidence to support prosecution. By its very nature the bribery of public officials is covert and generally involves consensual parties who go to great lengths to conceal the transaction. When the official involved is a representative of a foreign government and most of the critical acts take place outside of the country, the problems of detection, investigation and prosecution are necessarily compounded.

Letter from the DOJ to Hon. Harley O. Staggers, Chairman, Interstate and Foreign Commerce Committee, United States House of Representatives, April 20, 1977

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