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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: Snamprogetti

‘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

Country count for the top ten list

The FCPA Blog started publishing its list of the ten biggest FCPA corporate enforcement actions about a dozen years ago. Since then, I’ve written a lot about the top ten list, and I even did a series of talks, mainly in Asia, using the top ten list as a way to understand FCPA enforcement policy and attitudes toward compliance.… Continue Reading

Ryan Rohlfsen: How much will US v. Hoskins impact FCPA coverage?

On August 24, the United States Court of Appeals for the Second Circuit ruled that a non-resident foreign national cannot be held criminally liable for aiding or abetting or conspiring to violate the Foreign Corrupt Practices Act, unless the government can show that he acted as an agent of a “domestic concern” or while physically present in the United States.… Continue Reading

Alcoa disgorgement is third biggest in FCPA history

As part of its $354 million settlement this week, Alcoa agreed to pay the third biggest disgorgement in FCPA history — $161 million.

What is disgorgement? It’s a remedy, according to our contributing editor Marc Alain Bohn, authorized by the Securities Exchange Act of 1934 that’s ‘used to deprive wrong-doers of their ill-gotten gains and deter violations of federal securities law.’… Continue Reading

Alcoa lands 5th on our Top Ten list

Thursday’s $384 million enforcement action against Alcoa and one of its subsidiaries ranks 5th on our list of the Top Ten FCPA cases of all time.

With Pittsburgh-based Alcoa’s entry, two of the top ten cases now involve U.S.… Continue Reading