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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

Enforcement Report for Q2 ’13

It was blockbuster quarter for FCPA enforcement, and April was one of the busiest months on record.

There were five corporate resolutions, including the first-ever double non-prosecution agreements from the DOJ and SEC in the Ralph Lauren case. 

Total S.A.’s mega settlement cracked our Top Ten list, the first change to that list since late 2011.… Continue Reading

Corruption Risks — China Travel Edition (Part I)

In any country, paying for travel for government officials, customers at state-owned enterprises, or customers at purely private enterprises can present corruption risks. Many worthy publications have addressed travel risks generally and how to minimize those risks, including establishing a true business purpose for the trip, ensuring transparency with the recipient’s organization, pre-approving a detailed itinerary to ensure that sightseeing/leisure does not predominate, paying expenses directly to vendors where possible, avoiding unnecessary stopovers or family members or friends accompanying, etc.… Continue Reading

For corporate defendants, there will (probably) be blood

Some members of Congress are evidently concerned that corporate defendants are getting off the hook. Too many deferred- and non-prosecution agreements, and not enough criminal indictments.

So acting assistant AG Mythili Raman, who’s now heading the DOJ’s criminal division, testified Wednesday before the U.S.… Continue Reading

Disgorgement, an overlooked aspect of the Ralph Lauren settlement?

As part of its recent settlement with the SEC, Ralph Lauren Corporation agreed to disgorge $593,000 that was “obtained or retained as a result of the violations discovered during the investigation,” along with $141,846 in pre-judgment interest. 

$593,000 also happens to be precisely the same amount the SEC alleges that Ralph Lauren made in illicit bribe payments and gifts to Argentine officials from 2005-2009.… Continue Reading

Enforcement is back (if it ever left)

Acting Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division Did someone say FCPA enforcement had slowed down? Look again.

Already this month there have been settled enforcement actions involving Philips, Parker Drilling, and Ariel Sharef of Siemens, new charges unsealed against four former BizJet execs with two guilty pleas, and two Alstom execs with one guilty plea, and obstruction charges in a grand jury FCPA investigation.… Continue Reading