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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

Practice Alert: CFTC will investigate and prosecute FCPA violations

The Commodity Futures Trading Commission (CFTC) said Wednesday it will work alongside of the DOJ and SEC to investigate foreign bribery and prosecute overseas corruption offenses.

In a March 6 Enforcement Advisory (pdf), the CFTC’s Division of Enforcement said commodities companies that self report violations of the Commodity Exchange Act  involving foreign corrupt practices could receive declinations.… Continue Reading

FCPA enforcement report for Q2 2018

During the second calendar quarter, there were five corporate FCPA enforcement actions.

The settling companies paid a total of $985 million for the resolutions.

SocGen’s $585 million settlement grabbed a spot on our list of the biggest FCPA cases.… Continue Reading

Sanofi discloses DOJ declination in FCPA investigation

French pharma Sanofi said Wednesday the DOJ has closed an FCPA investigation that started four years ago.

The company said it heard from the DOJ in February.

But Sanofi said it is still cooperating with the SEC’s “review of the allegations.”

Sanofi disclosed in 2014 an investigation into possible illegal payments in the Middle East and Africa from 2007 to 2012, following allegations from an anonymous whistleblower.… Continue Reading

Andy Spalding: The Pilot Program as declination policy

We’ll spend a number of posts this month explaining what is good about the Pilot Program and what may be better. The last post explained the four (not three) requirements the Program establishes — voluntary disclosure, cooperation, remediation, and disgorgement — and how some of those terms have been carefully (re)defined.… Continue Reading