Paul E. Pelletier | The FCPA Blog

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All posts by Paul E. Pelletier

When It Absolutely, Positively Has to Be Indicted Overnight: How to Prevent Future Debacles Like the FedEx Prosecution

Paul E. Pelletier August 22, 2016

Against the backdrop of years of unprecedented monetary penalties imposed through DOJ civil settlements and deferred prosecution agreements with financial institutions embroiled in the 2008 financial meltdown, the DOJ came under withering criticism for perceptibly treating scrutinized corporations simply as cash cows rather than addressing the actual criminal conduct of the corporations and their executives.… Continue Reading

Paul Pelletier on the Search for Mr. Goodboss: Who Should be the Next FCPA Chief?

Paul E. Pelletier April 26, 2016

The recent announcement that DOJ is taking applications for the newly vacated FCPA Chief position provides a timely opportunity to reflect on the history, growth and direction of the Unit as well as a chance to consider the unique game-changing possibilities that await an accomplished selectee.… Continue Reading

Paul Pelletier: Sporadic enforcement isn’t effective enforcement

Paul E. Pelletier February 1, 2016

At a recent ubiquitous FCPA conference, Assistant Attorney General Leslie Caldwell noted that even more resources would be added to the Fraud Section’s FCPA Unit, increasing the number of prosecutors by 50% from 20 to 30 trial attorneys, making this specialty unit larger than the entire white collar sections of most United States Attorneys’ Offices nationwide.… Continue Reading

Paul Pelletier: Will the Yates Memo further delay corporate FCPA resolutions?

Paul E. Pelletier October 5, 2015

While the much heralded Yates Memo has produced a frenzy of “what does it mean?” reporting, few analysts have examined the depth and breadth of the issues and events that led DOJ to re-emphasize the focus on prosecution of corporate executives.… Continue Reading

Getting real: FCPA investigations shouldn’t ‘boil the ocean’

Paul E. Pelletier May 11, 2015

Companies that might become embroiled in seemingly perpetual DOJ FCPA investigations recently received some mixed messages from DOJ’s Criminal Division. On April 17, Leslie Caldwell, the AAG of the Criminal Division, delivered remarks at New York University Law School’s Program on Corporate Compliance and Enforcement.… Continue Reading