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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

Fresenius lands on our top ten disgorgement list

Last month’s $231 million FCPA resolution by German dialysis giant Fresenius Medical Care included disgorgement to the SEC of $147 million. By our count, that’s the tenth biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading

Petrobras tops new top ten disgorgement list

Petrobras’s $1.78 billion FCPA resolution last week included disgorgement of $933.5 million, the biggest ever ordered in an FCPA enforcement action.

The SEC allowed Petrobras to credit against the disgorgement the money it had already paid into a settlement fund for U.S.… Continue Reading

Telia also tops our new Top Ten Disgorgements list

Telia Company AB’s $965.6 million settlement Thursday included disgorgement to the SEC of $457 million, the biggest disgorgement ever ordered in an FCPA enforcement action.

Telia won’t actually pay the SEC $457 million in dsgorgement, however.… 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