News and commentary about white-collar crime, enforcement, and compliance
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
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
The Securities and Exchange Commission said Thursday that Charles Cain is the new Chief of the Enforcement Division’s Foreign Corrupt Practices Act Unit.
Cain has served as Acting Chief of the FCPA Unit since April 2017.… Continue Reading
Debevoise & Plimpton LLP said Monday that Kara Novaco Brockmeyer, former chief of the SEC’s Foreign Corrupt Practices Act Unit, is joining the firm’s Washington, DC office.
She’ll be a partner and member of the white collar, regulatory defense, and crisis response groups.… Continue Reading
When it was signed into law in 1977, the Foreign Corrupt Practices Act was very much an American approach to a global problem: how corruption in general and bribery in particular was skewing international business.… Continue Reading
The Securities and Exchange Commission said Tuesday that Kara Novaco Brockmeyer, Chief of the Enforcement Division’s Foreign Corrupt Practices Act Unit, is planning to leave the agency later this month.
Since 2011, Brockmeyer has led 38 lawyers at the SEC as well as staff accountants and other specialists focusing on violations of the anti-bribery and accounting provisions of the FCPA embedded in the federal securities laws.… Continue Reading
Last week, TRACE held its 13th Forum at the St. Regis Hotel in Washington, D.C. Over 100 member companies contributed to a lively and extended exchange of best practices across the two-day event.… Continue Reading
Secrets. We all have them. It’s human nature to keep them. But given recent enforcement actions initiated by whistleblowers, one thing is clear: a good secret has a high price tag.… Continue Reading
In the e-book we wrote as a guide to navigating corruption challenges in emerging markets, we talk in one chapter about the particular risks companies face when they enter new markets.… Continue Reading
The Securities and Exchange Commission Monday charged Tokyo-based conglomerate Hitachi, Ltd. with violating the Foreign Corrupt Practices Act when it inaccurately recorded improper payments to South Africa’s ruling political party in connection with contracts to build two multi-billion dollar power plants.… Continue Reading
The Securities and Exchange Commission Tuesday said BNY Mellon agreed to pay $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act by providing valuable student internships to family members of foreign government officials affiliated with a Middle Eastern sovereign wealth fund.… Continue Reading
Several articles over the past few days have reported that the DOJ and SEC are quietly revising A Resource Guide to the FCPA, the joint guidance the agencies issued on November 14, 2012, including one article that suggested these revisions occurred as recently as June of this year (see also here and here).… Continue Reading
Many of us scratched our head in 2010 when the Oracle FCPA enforcement action came out. We didn’t understand how a company could be prosecuted, even civilly by the SEC for internal controls or book and records violations, without evidence that bribes had been paid.… Continue Reading
At ACI’s annual FCPA Conference last November, SEC FCPA Unit Chief Kara N. Brockmeyer disclosed that the SEC expects to rely more frequently on administrative proceedings (as opposed to more traditional civil court actions) to resolve FCPA-related enforcement matters.… Continue Reading