Last month Rolls-Royce agreed in a deferred prosecution agreement with the DOJ to pay a fine of nearly $170 million for FCPA violations. What makes the Rolls-Royce DPA unique is that $30 million of the fine went to the Consumer Financial Fraud Fund (CFFF).… Continue Reading
Aaron Bornstein wrote in the prior post of the potential to use recovered bribe proceeds or stolen assets to fund BOTA-inspired programs in developing countries. That possibility is real, and important. … Continue Reading
We provided a number of examples in the prior post when the DOJ funded community service projects with settlement money while fully complying with the MRA. Indeed, these projects have become more common, not less, in recent years.… Continue Reading
We’ve heard it so many times: the Miscellaneous Receipts Act prohibits federal enforcement agencies from doing anything with settlement money other than depositing 100% of it in the U.S. Treasury.
But that simply isn’t true.… Continue Reading