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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 – Page 3

Sorry, but the NDAA did not just redefine disgorgement

[…] Congress recently passed the 2021 National Defense Authorization Act (NDAA), H.R. 6395. Buried over 1,000 pages into the bill is an amendment to the Securities Exchange Act of 1934. That amendment gives the Securities and Exchange Commission explicit statutory authority to seek disgorgement in federal district court. This grant of authority is significant, if […]

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Bribe Takers Get A Pass Under The FCPA

[…] the Foreign Corrupt Practices Act. Fortunately, a reader with time to ponder such things asked us that question after we reported last month (here) the FCPA-related sentencing of former World Bank employee, Ramendra Basu. Basu and his co-conspirator, Gautam Sengupta, another World Bank employee, pleaded guilty to helping a Swedish consultant make corrupt payments […]

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The FCPA’s Long Shadow

[…] to help, and continued to make periodic reports to the DOJ and SEC. It wasn’t until 2010 that the DOJ and SEC started talking about a settlement of FCPA offenses. The talks, Tyco said last week, are ‘ongoing.’ The statute of limitations for FCPA violations is five years. That means formal prosecution must be […]

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Here’s everything new in the Second Edition of the FCPA Resource Guide

The DOJ and SEC published the Second Edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act Friday, updating for the first time the best government-produced FCPA guidance. The FCPA Resource Guide was originally published in November 2012 and hasn’t been updated until now. A lot of important FCPA-related enforcement actions and […]

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Kleptocrats In Court

The United States fights foreign kleptocrats through Proclamation 7750, by denying them and their families U.S. visas. And through Section 314(a) of the Patriot Act, which it can use to reach out to more than 25,000 financial institutions to find accounts and transactions of anyone who may be involved in laundering kleptocratic assets. But […]

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Walmart’s Stitch In Time

Here’s a comment from Alexander Sierck, the lawyer for SERAP, about a different subject: ______________ Dear FCPA Blog,   Your April 30 post about statute of limitations issues in the Wal-Mart case was a good one, particularly regarding conspiracy. Here’s another point.  Under FCPA for the substantive crime of bribes or offers, the five-year […]

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Victor Kozeny’s Extradition From the Bahamas Is Denied

The Bahamas News Online Edition (The Bahama Journal) reports today that the Supreme Court there has ruled against the extradition of Victor Kozeny (left). The ruling means Kozeny is no longer under arrest in the Bahamas, which had detained him at the request of the U.S. government. He was indicted in the United States […]

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