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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

Flowserve Resolves Oil For Food Bribery Charges

French and Dutch Subsidiaries Paid Kickbacks and Caused FCPA Books and Records Violations

Texas-based Flowserve Corporation will pay about $10.5 million to resolve criminal and civil charges brought by the United States for illegal payments to Iraq under the U.N.… Continue Reading

Wabtec Resolves FCPA Violations Related To India

Westinghouse Air Brake Technologies Corporation (“Wabtec”) will pay about $675,000 and enter into a deferred prosecution agreement to resolve Foreign Corrupt Practices Act offenses caused by its Indian subsidiary, Pioneer Friction Limited.… Continue Reading

A.T. Kearney’s Former India President Violated The FCPA

The U.S. Securities and Exchange Commission announced on September 25, 2007 two settled enforcement actions based on violations of the books and records provisions of the Foreign Corrupt Practices Act. The actions involved the founder and former president of A.T.… Continue Reading

FCPA Defenses That Don’t Work

The text of the Foreign Corrupt Practices Act sets out three types of payments to foreign officials that are lawful — facilitating payments, promotional expenses and payments permitted under the written laws of the host country.… Continue Reading

The Long, Strong Arm of the FCPA

Its jurisdictional reach is legendary, but understanding exactly why the FCPA’s coverage stretches so far and wide is not always easy. One explanation comes from the United States Attorneys’ Manual, in this clear and sometimes ominous exposition:

Under the FCPA, U.S.

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Textron’s FCPA Violations Caused by Fifth Tier French Subsidiaries

Textron Inc., without admitting or denying books and records and internal controls allegations, consented to the entry of a final judgment with the SEC permanently enjoining it from future violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934, ordering it to disgorge $2,284,579 in profits, plus $450,461.68… Continue Reading