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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

Posts Tagged: Disgorgement Top Ten

Halliburton Investigating Angola Operations

Houston-based oil and gas services giant Halliburton on Friday disclosed an internal investigation into possible Foreign Corrupt Practices Act violations in Angola.

It said in an SEC filing that an anonymous email it received in December 2010 alleged FCPA violations ‘principally through the use of an Angolan vendor.’… Continue Reading

In FCPA Sentencings, What’s A ‘Benefit Received’?

By Dr. Patrick Conroy and Dr. Graeme Hunter

Fines and disgorgements for FCPA offenses are based on the “benefit received” from a bribe.

With those penalties now reaching hundreds of millions of dollars and with increasing enforcement, it’s important to understand what effect a bribe had on profits, and to carefully establish what the but-for profits would have been without the bribe.… Continue Reading

Hey, Tesler Belongs In Top Ten

We love the mailbag. Yesterday a reader said: “While the Tesler plea is a $149 million forfeiture, it seems to me that it should make your Top 10.”

Jeffrey Tesler, 61, former middleman to KBR and its TSKJ partners Snamprogetti, Technip, and JGC, pleaded guilty in federal court in Houston in March to conspiracy and violating the FCPA.… Continue Reading

IBM Pays $10 Million In SEC Settlement

IBM today resolved civil charges brought by the SEC for violating the books and records and internal control provisions of the Foreign Corrupt Practices Act.

The company admitted making improper cash payments to government officials in South Korea and China, and giving gifts and paying travel and entertainment expenses that violated the FCPA.… Continue Reading

What Exactly is Disgorgement?

Marc Alain Bohn: Disgorgement is technically not intended as a tool to punish.As noted by the FCPA Blog earlier this week, disgorgement has quietly become a potent and heavily relied on aspect of the SEC’s FCPA enforcement strategy in recent years.… Continue Reading

Top Ten Disgorgements

There’s been a lot of talk lately about the DOJ’s “expansive enforcement practices” and practically none about the SEC’s. So let’s get started by taking a look at a remedy the SEC now uses in most FCPA cases: disgorgement.… Continue Reading