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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/Statute of Limitations

Four ways the DOJ sidesteps the FCPA statute of limitations

In February, the Department of Justice unsealed an indictment against two former executives of the Indonesian subsidiary of Alstom S.A., Reza Moenaf and Eko Sulianto, and a former executive of Marubeni Corporation, Junji Kusunoki. Both companies pleaded guilty to foreign bribery charges in 2014 and racked up substantial penalties partly as a result of […]

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AON Discloses FCPA Investigation

It Has Already Agreed to Toll the Statute of Limitations; Will Self-Reporting Lead to More Waivers of Legal Protections? Aon Corporation — the world’s biggest insurance broker — disclosed on November 8, 2007 an internal investigation of possible violations of the U.S. Foreign Corrupt Practices Act and non-U.S. anticorruption laws. AON said in its […]

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Why is ‘ancient history’ part of so many FCPA cases?

[…] ago, and one case involved illegal conduct that started 14 years ago. Here are some reasons why there’s so much ancient history in FCPA cases: The statute of limitations for FCPA offenses. The DOJ has five years in which to formally commence criminal prosecutions under the FCPA’s anti-bribery provisions, and six years under the […]

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Shorter clock on SEC’s FCPA enforcement actions

Last week, in the case Gabelli v. SEC, the U.S. Supreme Court unanimously held that the Securities and Exchange Commission, when seeking a penalty or fine in connection with a civil enforcement action, must file the action within five years of the completion of the alleged fraud or wrongful conduct.

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