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Editors

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Harry Cassin
Publisher and Editor

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Andy Spalding
Senior Editor

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Jessica Tillipman
Senior Editor

WILLIAM B.F. STEINMAN

Bill Steinman
Senior Editor

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Richard L. Cassin
Editor at Large

Elizabeth K. Spahn

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington

Cody Worthington
Contributing Editor

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Julie DiMauro
Contributing Editor

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Thomas Fox
Contributing Editor

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Marc Alain Bohn
Contributing Editor

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Bill Waite
Contributing Editor

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Shruti J. Shah
Contributing Editor

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Russell A. Stamets
Contributing Editor

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Richard Bistrong
Contributing Editor

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Eric Carlson
Contributing Editor

Total carries forward $398 million for possible FCPA settlement

Richard L. Cassin April 29, 2013

Here’s the complete FCPA disclosure from Total SA’s Form 6-K (Report of Foreign Private Issuer) filed with the SEC on April 29, 2013:

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In 2003, the United States Securities and Exchange Commission (SEC) followed by the Department of Justice (DoJ) issued a formal order directing an investigation in connection with the pursuit of business in Iran by certain oil companies including, among others, TOTAL.… Continue Reading

Total on trial for oil-for-food violations

Richard L. Cassin January 28, 2013

The French oil giant Total SA is on trial in Paris for violating the United Nations oil-for-food program.

Total is accused of buying oil directly from the former Saddam Hussien regime in violation of the U.N.… Continue Reading

Spanish pharma wins DOJ declination

The FCPA Blog December 7, 2012

In an SEC filing this week, Spanish pharmaceutical firm Grifols SA said the DOJ issued an ‘official declination to all inquiries related to the possible violation of the Foreign Corrupt Practices Act (FCPA) that were underway since July 2009.’… Continue Reading

The FCPA versus global terrorism

Richard L. Cassin December 7, 2012

Innovative uses of anti-corruption laws to fight terrorists and tyrants and companies that help them is the subject of a breakthrough article published this week by the Wharton School of the University of Pennsylvania.… Continue Reading

Total SA heads for the top ten

Richard L. Cassin November 7, 2012

French oil giant Total SA said in its third quarter results it has reserved $398 million for an FCPA settlement with the DOJ and SEC.

U.S. enforcement agencies have been investigating Total’s operations in Iran since 2003.… Continue Reading

A Prince Of Persia

Richard L. Cassin May 19, 2010

Iran has all the ingredients to be an FCPA minefield. It’s big — 66 million people in an area about the size of Alaska — and it’s the world’s 6th largest oil producer.… Continue Reading

BAE: Bribery, Bombs And Black Knights

Richard L. Cassin February 16, 2010

Photo by Annie MoleIs there a place where anti-corruption policy stops and international politics begins? Andy Spalding — a lawyer and Fulbright scholar who’s a familiar face around here — thinks so.… Continue Reading

Giving Thanks Once Again

Richard L. Cassin November 19, 2009

During this season of Thanksgiving, the folks at Norway’s Statoil ASA will be celebrating the end of the company’s three-year deferred prosecution agreement — and the Justice Department’s public announcement about it here.… Continue Reading

The Statecraft Of Enforcement

Richard L. Cassin September 28, 2009

Should the Foreign Corrupt Practices Act be used to punish nations that don’t behave the way the United States wants them to? Michael Jacobson (left) from the Washington Institute thinks so.… Continue Reading