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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

Search Results for: label/Private Right of Action – Page 2

What did WeWork teach us about ‘private-company’ compliance?

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 […]

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Mike Scher: Let’s hang together to fight graft

[…] 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 […]

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The False Claims Act: A primer for whistleblowers

[…] from a DOJ white paper.
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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 […]

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Prosecuting Private Overseas Corruption

[…] 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 […]

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Petrobras smashes the top ten list (and we explain why)

[…] 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 […]

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Martin Kenney: Open company UBO registers are not the panacea to financial crime

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 […]

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More Hurdles For Private Litigants

[…] 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 […]

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