The DOJ and SEC have prosecuted 240 different companies (by my count) for FCPA offenses. Of those 240 companies, 13 have been repeat FCPA defendants. That means the recidivism rate for all corporate FCPA defendants is about 5.5 percent.… Continue Reading
Posts Tagged: deterrence
A few weeks ago, I read about an “exasperated federal judge” at the sentencing of Samuel Mebiame, the 43-year-old son of the former prime minister of Gabon, who was an intermediary for Och-Ziff. … Continue Reading
The OECD is hosting an Anti-Bribery Ministerial meeting Wednesday (March 16) to discuss how to strengthen implementation of its Anti-Bribery Convention. One of the issues on the table for discussion is how to encourage voluntary disclosure by companies of wrongdoing and how settlements can be used to do that.… Continue Reading
In a New York Times op-ed, former assistant U.S. attorney Eric Havian recommended using better methods to deter corporate misbehavior. “Exclusion,” he said, “needs to be dusted off, modernized and used more frequently.”… Continue Reading
The story of Vicente Garcia, SAP’s former head of sales for Latin America, reminded me of one of the darkest periods in my life — the time before sentencing.