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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
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Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
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Marc Alain Bohn
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Bill Waite
Contributing Editor

Shruti J. Shah
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Russell A. Stamets
Contributing Editor

Richard Bistrong
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Eric Carlson
Contributing Editor

BizJet’s High Flying Cooperation Dividend

When BizJet paid $11.8 million this week to settle an FCPA conspiracy count, it received a huge discount from the DOJ.

According to the Federal Sentencing Guidelines, BizJet’s base fine calculation was $28.5 million.

After applying so-called ‘multipliers,’ the fine range was $17.1 million to $34.2 million.

So BizJet’s reduction was 30% off the bottom of the fine range, and a whopping 65% off the top of the fine range.

How’d that happen?

The deferred prosecution agreement said:

‘BizJet and the [DOJ] agree that this fine is appropriate given the facts and circumstances of this case, including the nature and extent of BizJet’s voluntary disclosure, extraordinary cooperation, and extensive remediation in this matter. The $11,800,000 is final . . . . ‘


BizJet’s March 14, 2012 deferred prosecution agreement with the DOJ can be downloaded here (pdf).

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