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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
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Shruti J. Shah
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
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Posts Tagged: Foreign Official

Hitting the highpoints with the DOJ

Gifts, travel and entertainment, foreign officials, successor liability, and effective compliance programs.

They’re among the topics covered by the new 120-page joint DOJ and SEC guidance on the FCPA.

In the fact sheet accompanying the guidance, the DOJ summarized its position on those topics.… Continue Reading

Tyco in $26 million settlement with DOJ and SEC

Tyco International Ltd. agreed on Monday to pay criminal and civil penalties totaling more than $26 million to resolve Foreign Corrupt Practices Act violations.

The Switzerland-based maker of fire security products paid more than $13.6 million in criminal penalties to the DOJ, and $13 million in civil penalties to the SEC.… Continue Reading

Autumnal Adventures to Unchartered Corners

The passing of Labor Day marks the advent of a new season. In my new home state of Virginia, the heat has softened and the riverside trees take on a faint yellow; for our friends in the Southern Hemisphere, perhaps the winter wanes and blossoms bud.… Continue Reading

DOJ Answers Esquenazi and Rodriguez

The appeal by Carlos Rodriguez and Joel Esquenazi of their FCPA convictions is now with the 11th Circuit Court of Appeals.

As Mike Koehler noted in his post today (and in prior coverage), ‘this is a historic appeal, the first time in the FCPA’s history that “foreign official” will be squarely before an appellate court.’… Continue Reading

The Hunt For Public International Organizations

After it signed the OECD Anti-Bribery Convention, the U.S. in 1998 amended the FCPA through the International Anti-Bribery and Fair Competition Act. Among other things, the 1998 amendment widened the definition of “foreign official” to include any officer or employee of a public international organization or any person acting in an official capacity for, or on behalf of, any such public international organization.… Continue Reading

Tell Us: Are NGOs Instrumentalities?

The first chapter of my thesis analyzed the definitions of “foreign public official” in the FCPA and several international anti-bribery conventions. Included in the definitions are the personnel of public international organizations.… Continue Reading