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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

A plea to Mr. Holder: Help corruption’s victims

U.S. Attorney General Eric Holder (Image courtesy of the DOJ)The movement to use anticorruption enforcement proceeds for the benefit of corruption’s true victims is gaining ever more momentum.

The UNCAC Coalition —  a global network of over 350 civil society organisations in over 100 countries, committed to promoting the ratification, implementation and monitoring of the UN Convention Against Corruption — has recently drafted a letter to U.S.… Continue Reading

It’s Simple: The Nigerian Money is the Nigerians’ Money

Friends of the FCPA Blog — Sandy Sierck and Nick Diamond, who represent the Socio-Economic Rights and Accountability Project in Nigeria — have another good idea. For years, SERAP has been petitioning the DOJ and SEC to return enforcement revenues to the real victims of overseas corruption: the citizens of the corrupt governments.… Continue Reading

To Mexico, from Nigeria, via Kazakhstan: On the Trail of a Great Idea (Part 2)

Last post, I discussed the proposal from Nigeria’s Social-Economic Rights and Accountability Project to establish a mechanism for using the proceeds of FCPA settlements to help bribery victims. Specifically, SERAP suggests that civil penalty or disgorgement proceeds be made available to civil-society groups in the victimized country, or to U.S.-based NGOs serving that country, to fund public benefit projects subject to anti-corruption safeguards.… Continue Reading

Handling Naaman’s Secret Evidence

As we mentioned a few weeks ago, Ousama Naaman’s sentencing is on hold while he and the government review new evidence that may be classified.

It’s a complicated process, and prosecutors now want his sentencing, first set for August 4 and then moved to September 8, delayed indefinitely.… Continue Reading

Worst FCPA Prosecutions Ever

We have enormous respect for those who serve the public, including the prosecutors at the DOJ. Without them, the ‘rule of law’ would just be pretty words.

But everyone is human and stuff happens.… Continue Reading

FCPA Defendants Face The Verdict Of History

Should anyone be surprised by the guilty verdicts handed down Tuesday in the Lindsey case?

Not at all. History, and the odds, are always against FCPA defendants.

Others who’ve learned that in recent years include Gerald Green and his wife Patricia, Frederic Bourke, William Jefferson, David Kay, Douglas Murphy, and David Mead — all convicted by juries in FCPA cases. 

Oil consultant James Giffen beat an FCPA rap and pleaded guilty to a misdemeanor tax charge, but only after the CIA apparently admitted that he and the agency had a close working relationship in Kazakhstan.… Continue Reading

Wikileaks, SEC Whistleblowers, and Giffen

For years now, a certain reader has been stitching together for us enforcement topics in ways we hadn’t thought of.

This time our friend — who’s a top compliance professional and wants to remain anonymous — connects the dots from a few recent headlines.… Continue Reading

No Punishment For ‘Hero’ Giffen

Kazakhstani President Nursultan Nazarbayev with then U.S. President George W. Bush, 2006. Photo credt to WikipediaOil consultant James H. Giffen, once accused of paying $84 million in bribes to the president of Kazakhstan and other foreign officials, wasn’t punished for a misdemeanor tax charge he pleaded guilty to in August to end his case.… Continue Reading

Is The Giffen Case America’s BAE?

We’re always happy to hear from lawyer Andy Spalding, left. He recently returned from a year-long Fulbright Research Grant in Mumbai, India, and is now on the faculty at the Chicago-Kent College of Law.… Continue Reading