Posts Tagged: Pilot Program
Sam RubenfeldLate last month, reporter and editor Sam Rubenfeld announced via Twitter that after ten years, he was leaving the Wall Street Journal.
He joined the Journal fresh out of college and quickly found his way to the Corruption Currents blog, while also editing and writing for the Dow Jones Newsletters and Newswires.… Continue Reading
The prosecutor who oversees the criminal division’s FCPA unit said the DOJ wants corporate acquisitions to happen and doesn’t want the “specter of enforcement to be a risk factor that impedes such activity by good actors.”… Continue Reading
Russian President Putin recently submitted a new anti-corruption bill to the Russian parliament.
The proposal has two significant aspects.
First, it would amend Article 19.28 of the Russian Code of Administrative Violations (which was previously amended in 2011 to impose liability on corporations for bribery, including domestic and foreign, public and private) to provide that companies can avoid liability in domestic bribery cases if
(i) they assist in the discovery or investigation of the bribe or
(ii) the bribe has been extorted. … Continue Reading
By almost any measure, the new FCPA enforcement policy is an important and positive development. Tom Fox, Bill Steinman, George Terwilliger, and others both here and beyond have noted as much, and I rise in concurrence.… Continue Reading
FCPA investigators routinely face obstacles to gathering data from non-company email and messaging apps. In particular, such communications are often not stored on company devices, and where files exist, they may be encrypted or otherwise difficult to open. … Continue Reading
I recently spoke with David M. Stuart, one of the attorneys who represented Telia Company AB, a Sweden-based telecommunications provider that settled violations in September for a grand total of $965 million in financial sanctions.… Continue Reading
Deputy Attorney General Rod Rosenstein’s announcement of a permanent expansion of the Department of Justice Foreign Corrupt Practices Act “Pilot Program” is good news for companies that repeatedly faced the dilemma of whether or not to investigate and disclose FCPA issues discovered internally.… Continue Reading
FCPA practitioners welcomed Rod Rosenstein’s announcement that the Department of Justice has made the FCPA Pilot Program permanent, and incorporated it into the U.S. Attorneys’ Manual. In the words of one of my colleagues, the audience “noticeably lightened up” at the Deputy AG’s news. … Continue Reading
At a recent conference, I had the good fortune of asking a former high-ranking DOJ official, “how is it that pre-existing compliance is no part of the Pilot Program’s penalty reductions and declinations?”… Continue Reading