News and commentary about white-collar crime, enforcement, and compliance
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
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
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
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
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
There was just one corporate enforcement action during the second quarter of the year. During the same period last year, there were five, and two in 2010.
But the Morgan Stanley declination made big news during the second quarter.… Continue Reading
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
The CEOs, CFOs, COOs and Chief Compliance Officers we meet with are well aware of the FCPA and are working to put in place compliance programs to keep their companies on the right side of the law, but they are not terribly concerned about their own personal exposures.… Continue Reading
Yesterday we posted our 2011 FCPA enforcement index. Today we look at corporate enforcement for the years from 2006.
Here goes:
In 2011, 15 companies paid $508.6 million in criminal and civil penalties, and in disgorgement and interest.… Continue Reading
Fifteen companies settled FCPA enforcement actions in 2011 by paying a total of $508.6 million.… Continue Reading
Some picks for the year’s hottest FCPA headlines are these:
#1: Drop in corporate enforcement actions. In 2010, 23 companies settled FCPA cases for $1.8 billion; in 2011, just 15 companies settled for $508.6 million.… Continue Reading
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
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
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