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
the Basel Institute on Governance will hold its 3rd Anti-Corruption Collective Action Conference on November 14 – 15, 2018 in Basel, Switzerland.
As the leader of a private company, WeWork’s former CEO Adam Neumann clearly wasn’t subject to strong expense reporting requirements or conflicts of interest processes — he threw extravagant parties, routinely hired his family members and close friends, and engaged in numerous related-party transactions. But as Neumann and WeWork learned, those lax standards, often […]
[…] want the biggest bribe to win the business, not the best price, product or service.
The way to stop the bribery arms race is for all of the competitors to refuse to pay the bribes. This collective action is the key to fighting local and global graft. Acting collectively to resist corruption takes […]
[…] from a DOJ white paper.
* * *
The False Claims Act (FCA), 31 U.S.C. §§ 3729 – 3733 was enacted in 1863 by a Congress concerned that suppliers of goods to the Union Army during the Civil War were defrauding the Army. The FCA provided that any person who knowingly submitted false claims to the […]
[…] private parties. When did that become a federal offense? Well, it happened this year when the Justice Department indicted California valve-maker Control Components Inc. (CCI) and six of its former employees. Here’s how.
They were all charged under both the FCPA and the Travel Act (18 U.S. C. §1952). The latter prohibits traveling between states […]
[…] in history Thursday after the DOJ and SEC assessed penalties and disgorgement totalling $1.78 billion.
Petrobras’s non-prosecution agreement with the DOJ included a criminal penalty of $853.2 million. An SEC administrative order required disgorgement of $933.5 million.
All of the disgorgement was offset by payments Petrobras had already made to the settlement […]
Compliance and Collective Action program.
whistleblower. Casino-gaming company International Gaming Technology (IGT) agreed to pay a $500,000 penalty to settle the SEC’s enforcement action.
Predictably, the NGO “transparency” brigade has once again raised its guns and placed its cross-hairs over its preferred target: the offshore service providers in the British Overseas Territories, particularly those in the Caribbean. Only this time, they appear to have coerced and cajoled the support of a split, and apparently hesitant, UK […]
[…] directly. It’s interesting nonetheless because it raises the bar for private litigants wanting to sue management based on FCPA violations. As we’ve said before, there’s no private right of action under the FCPA itself and private litigants seeking relief have to resort to other causes of action — such as common law fraud, RICO […]
