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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

China Deals Trigger Investigation

In an SEC filing this week, Morgan Stanley disclosed (here) that it’s investigating possible Foreign Corrupt Practices Act violations in China. The bank said in a short statement that “it has recently uncovered actions initiated by an employee based in China in an overseas real estate subsidiary that appear to have violated the Foreign Corrupt Practices Act.… Continue Reading

I’d Want My Conscience

It may seem to Liberians as though everyone in their civil service is corrupt, but it’s not true. There’s at least one honest man. He’s Richard Karyea, a former customs officer at the Roberts International Airport.… Continue Reading

KBR’s Twisted Web

We’ve been looking over the criminal information charging Kellogg, Brown & Root LLC with violating the Foreign Corrupt Practices Act. There’s one conspiracy and four substantive counts. There’s also a related document called the Joint Motion to Waive Presentence Investigation.… Continue Reading

KBR Nears Final Plea Deal

A criminal information filed in federal court in Houston on Friday shows that Kellogg, Brown & Root LLC, the Houston-based global engineering and construction firm that was once part of Halliburton, will plead guilty to violating the Foreign Corrupt Practices Act.… Continue Reading

The DOJ Contra Mundum

Six months ago, without fanfare, the Justice Department scrapped the McNulty Memo. It was replaced by new guidance for federal prosecutors about charging corporate organizations with crimes, including violations of the Foreign Corrupt Practices Act.… Continue Reading

A Bit Of An Old Boy’s Club

The U.K.’s Serious Fraud Office was created in 1988 with the mission to investigate and prosecute big-time fraud and corruption — the misdeeds, as Teddy Roosevelt would have said, of the wealthy criminal class.… Continue Reading

It’s A Start

We’ve never come across any good news to report about Japan’s overseas anticorruption enforcement. Until now, that is. Last Thursday, according to an AFP report, a court in Tokyo convicted three former executives and their consulting company for bribery in Vietnam.… Continue Reading

Off Topic And On

Our colleague, Paul Oki, sent this note from Nigeria a few days ago: Would it surprise you if I told you that even now it’s not unusual to find cars with Obama campaign stickers plying our roads?Continue Reading

The Hunt For Overseas Evidence

No corporations and just a few individuals have fought Foreign Corrupt Practices Act charges in court, so only a handful of people have ever seen an FCPA defense up close. But for the first time, we have a chance to follow not one but three pending prosecutions — in U.S.v.Continue Reading

Dealing With The DOJ

The Justice Department resolves corporate FCPA enforcement actions these days by using deferred and non-prosecution agreements. And the go-to guys for information about them are Ryan McConnell, an Assistant United States Attorney in Houston, and Larry Finder, a partner in Houston with Haynes and Boone.… Continue Reading