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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

2013 FCPA Enforcement Index

In 2013, twelve companies paid $731.1 million to resolve FCPA cases (that includes IBM’s $10 million settlement from 2011 that received final court approval in 2013). Two of the twelve corporate actions — Total SA and Weatherford — landed in the top ten FCPA cases of all time.… Continue Reading

Where to (always) find our lists

We’re crazy about lists and they appear in this space often.

But for readers, finding the latest version of our lists can be hard.

So we’ve found them a permanent home.… Continue Reading

Our reference section (October 2012)

Here are some of the reports, indexes, and lists we maintain. They’re always free, thanks to the generous support of our sponsors.

The top group are published on a regular schedule.… Continue Reading

Enforcement Report For Q1 ’12

There were four FCPA corporate enforcement actions during the first quarter of the year (we lump parent and subsidiary companies together). That’s a normal amount of activity. In both 2011 and 2010, there were also four corporate actions during the same period.… Continue Reading

2011 Enforcement Index

Fifteen companies settled FCPA enforcement actions in 2011 by paying a total of $508.6 million.

(In 2010, 23 companies paid $1.8 billion. In 2009, 11 companies paid $644 million.… Continue Reading

Sixty-Four Million Reasons To Comply

Since the start of 2008, 58 companies (by our count) have settled FCPA-related enforcement actions with the DOJ or SEC or both. Together they paid $3.74 billion in penalties, disgorgement, and interest — an average of $64.5 million per enforcement action.… Continue Reading

Enforcement Report For Q-3 ’11

During the calendar quarter just ended, there were three corporate enforcement actions and two individual convictions. A defendant received one of the FCPA’s longest jail sentences, the DOJ released three new FCPA-related indictments, and prosecutors dropped the appeal of a short FCPA prison term.… Continue Reading

Scholarship That Rocked The Boat

A few years ago, after a dozen or so enterprising law students asked me what FCPA-related topics were ripe for research, I answered with a post on the FCPA Blog.

My suggestions included: (1) respondeat superior—the legal doctrine imputing to corporate employers the criminal acts of employees; (2) the sad state of the Department of Justice’s Opinion Procedure Releases; and (3) the confusing condition of the FCPA’s promotional-expenses affirmative defense.… Continue Reading

2010 FCPA Enforcement Index

Companies settling FCPA-related charges in 2010 paid a record $1.8 billion in financial penalties to the DOJ and SEC. That compares with $641 million in 2009 and $890 million in 2008, the year of Siemens’ $800 million settlement, still the largest ever.… Continue Reading