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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

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The Curious Case Of The Cautious Requestor

A typical reader of this blog will tell you that he or she is reasonably prudent when it comes to complying with the Foreign Corrupt Practices Act. But we’re all downright reckless compared with the sweet lady who stars in the most recent FCPA Opinion Procedure Release. She needed to pay $9,000 to a […]

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Get ready for human trafficking compliance

[…] order to protect the Government’s interest; (2) except as provided in subsection (a)(3) of this section, ensure that provisions in solicitations and clauses in contracts and subcontracts, where the estimated value of the supplies acquired or services required to be performed outside the United States exceeds $500,000, include the following requirements pertaining to the […]

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Did the DOJ go too far on the ‘thorny issue’ of jailed employees?

[…] free the employee. How companies handle this scenario varies, often depending on the perceived justification of the incarceration. A company may be willing to make a payment where it is clear the employee was jailed simply so that the police could extort a payment and refuse to make a payment where it seems likely […]

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Practice Note: UK appeals court puts new limits on notification injunctions

[…] aside. On April 8, 2016, Nugee J. granted an injunction to prevent the brothers from dealing with, disposing of, or otherwise engaging in transactions with their assets, where the value exceeded £1 million ($1.25 million), without providing written notice to Holyoake’s solicitors. Thus, a notification injunction. The court adjourned the remainder of the application, […]

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Wendt and Sultan on oral downloads: What should counsel share with the SEC?

In prior posts, we covered (1) how two former General Cable executives, now defendants in an SEC enforcement action, sought to compel Morgan Lewis (General Cable’s counsel) to share interview memoranda and notes, investigation reports and other materials from the firm’s internal investigation, and (2) how Judge Jonathan Goodman ruled in the defendants’ favor […]

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New FCPA Opinion Procedure Release brings an interesting twist on the extortion defense

[…] more severe than the prevailing norms in the United States. For example, many countries ban the possession or consumption of alcohol. I’ve encountered situations over the years where a client employee has been arrested for public intoxication or for possessing liquor in such a jurisdiction and been whisked off to prison. In some instances, […]

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