Last week, the U.S. Department of Justice announced a new “China Initiative.” According to the press release, the Initiative “reflects the Department’s strategic priority of countering Chinese national security threats and reinforces the President’s overall national security strategy.”… Continue Reading
In the days following President-elect Donald Trump’s announcement of his intention to nominate Sullivan & Cromwell partner Jay Clayton as Chair of the Securities and Exchange Commission, countless observers have opined on how the SEC’s priorities may change in the upcoming administration.… Continue Reading
DOJ criminal division chief Leslie Caldwell used a wide-ranging talk Thursday at George Washington University Law School to defend the six-month old Pilot Program and to describe the Justice Department’s FCPA enforcement efforts and the current state of corporate compliance.… Continue Reading
In contrast with most other public officials, relevant national laws prohibit employees of the intelligence community and the military from disclosing wrongdoing to a designated third party independent from the relevant organization.… Continue Reading
In her excellent book, Thieves of State, Sarah Chayes argues persuasively that foreign corruption is a threat to U.S. national security because it drives people to radical Islam. There is an additional aspect to this problem: corrupt regimes are a national security threat because they start wars in order to divert attention from their own corruption.… Continue Reading
The story of the failed FCPA prosecution of James Giffen is likely familiar to many readers of the FCPA Blog. Following a three-year investigation by the DOJ that started in 1999, in March 2003 Giffen was arrested as he was boarding a Paris bound plane at JFK.… Continue Reading
There still seems to be some debate as to whether the FCPA, the UK Bribery Act, and other international focused anti-bribery legislation aids in the fight against terrorism. But the continuum from corruption to crime to terrorism is well-established and arguing that laws such as the FCPA have no place in a country’s overall security regime seems to be me to be naive at best.… Continue Reading
At Duke’s law school Thursday in Durham, North Carolina, Leslie Caldwell, the chief of the DOJ’s criminal division, talked about international crime and enforcement. She covered the fight against cybercrime, kleptocrats and their assets, Libor rigging, sanctions offenses, human trafficking and child exploitation, and corruption.… Continue Reading
David A. O’Neil was appointed Acting Assistant Attorney General for the Criminal Division on March 21, 2014.
He replaced Mythili Raman. She held the job for only a year. But during her tenure the DOJ charged more than a dozen individuals for FCPA-related violations and secured three of the ten biggest corporate FCPA resolutions ever.… Continue Reading
Here’s an excerpt from Attorney General Eric Holder’s remarks Monday at the Arab Forum on Asset Recovery in Morocco.
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In recent years, we’ve joined hands to draft and bring into force the United Nations Convention Against Corruption – the first global anti-corruption treaty.… Continue Reading