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
As readers of the FCPA Blog are aware, the Pilot Program requires voluntary self-disclosure and cooperation with the government in order to be eligible for a declination from the DOJ.
Since the Pilot Program’s inception, three public companies have disgorged profits to the Securities and Exchange Commission in return for a declination from the DOJ.… Continue Reading
The most important thing for a company to remember when dealing with the Gross Human Rights Abuse provisions of the Criminal Finances Act is that they appear to be designed as a strict liability regime with no statutory defenses available.… Continue Reading
In August 2013, Brazil’s game-changing Clean Companies Act introduced the leniency agreement, a deferred prosecution deal for companies willing to plead guilty and settle corruption charges.
While these agreements were created to encourage cooperation, the Clean Companies Act or CCA (Law No.… Continue Reading
