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Editors

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

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Posts Tagged: Petrobras

These are the biggest FCPA cases for each of the past ten years

The biggest FCPA resolutions yearly show enormous variation and no predictable pattern. Although four of the biggest cases for each of the past ten years settled for more than $1 billion, with an overall average settlement size for the ten cases of about $996 million, a couple of years were laggards.… Continue Reading

‘Authorizing’ is at the center of most FCPA cases

Corporate subsidiaries only act on someone else’s say so. The drafters of the FCPA knew that, and that’s why the FCPA prohibits offering to pay, paying, promising to pay, or authorizing the payment of money or anything of value to a foreign official for an improper purpose.… Continue Reading

State-Granted Monopolies: Are they your best (and worst) customers?

They are so familiar to those of us who follow FCPA enforcement actions that we’re likely to stop noticing them. Petrobras in Brazil, Corpoelec and PDVSA in Venezuela, Pemex and CFE in Mexico, Takilant in Uzbekistan, Sonangol in Angola, Alba in Bahrain, Telecommunications D’Haiti, 1MDB in Malaysia, and Pertamina in Indonesia.… Continue Reading

Was Amec Foster Wheeler ‘afraid’ of its agents?

It’s a strange scenario. How did London-based Amec Foster Wheeler (AFW) end up with agents in three different countries for a single, relatively small project in Brazil — including two agents disqualified by AFW’s due diligence and a third agent that AFW thought had lost influence?… Continue Reading

Why companies are ‘undervaluing’ their FCPA exposure

I recently conducted a virtual training session, during which I displayed a slide showing the top ten FCPA fines and penalties in history. A curious attendee asked whether my figures represent the DOJ and SEC’s gross penalties or the amounts that companies were actually obliged to pay to the U.S.Continue Reading