Skip to content

Editors

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: Foreign Official

Esquenazi loses appeal in ‘foreign official’ case

A federal appeals court Friday affirmed the DOJ’s expansive view of a “foreign official” under the FCPA, upholding Joel Esquenazi and Carlos Rodriguez’s convictions, and keeping intact the longest prison sentence ever imposed in an FCPA case.… Continue Reading

Did Dennis Rodman violate the FCPA?

Among the more than $10,000 in gifts Dennis Rodman delivered to North Korea dictator Kim Jong Un in Pyongyang this month were “hundreds of dollars’ worth of Irish Jameson whiskey, European crystal, an Italian suit, a fur coat, and an English Mulberry handbag for Kim’s wife, Ri Sol-ju,” the Daily Beast said Friday.… Continue Reading

In year’s first FCPA opinion, DOJ clears ‘humanitarian aid’

On December 19, the Justice Department published FCPA Opinion Procedure Release No. 13-01, ruling that a law firm partner could pay some medical expenses of foreign official’s daughter.

The lawyer’s firm billed the foreign country over $2 million for the past 18 months, and expects to bill the same amount in 2014.… Continue Reading

‘Foreign official’ arguments in appeals court

The U.S. Court of Appeals for the 11th Circuit will hear oral arguments Friday from two defendants convicted in the Haiti telco case. They’re challenging the DOJ’s interpretation of ‘foreign official’ under the Foreign Corrupt Practices Act.… Continue Reading

Cameo Corruption, Conclusion: Zero Dark Third-Party Intermediaries

In the previous four posts, we examined how the practice of allowing public officials to appear in films could be used as an alternative method of bribery. While we’ve focused on the idea of a foreign official receiving a cameo, the analysis actually applies to anyone who has a substantial enough connection to a foreign official.… Continue Reading