News and commentary about white-collar crime, enforcement, and compliance
Harry Cassin
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Bill Steinman
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Richard L. Cassin
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Elizabeth K. Spahn
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Cody Worthington
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
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Let’s recap. In my first post, I examined a limited set of circumstances where I believe it is reasonable under the FCPA to pay per diems to foreign officials.
In my second post, I looked at the enforcement agencies’ take on per diems by analyzing the FCPA Resource Guide as well as the Opinion Procedure Releases where the DOJ found it appropriate to make cash payments to foreign officials.… Continue Reading
There’s always a danger that an unhealthy corporate practice, even an illegal one, will gain internal acceptance and legitimacy simply because it happens all the time.
Take Diageo’s gift giving in Asia.… Continue Reading
By Thomas Fox
As December is a time for reflection on the past twelve months, I have been considering the FCPA year. I submit for your consideration my Top 10 Favorite FCPA Enforcement Actions for 2010.… Continue Reading
By Jeffrey M. Kaplan
Since 1991 –- even prior to the Sentencing Guidelines going into effect -– Justice Department officials have said corporate charging decisions should be based in part on how effective a corporation’s compliance program was at the time of the offense in question.… Continue Reading
In an unusual tandem settlement, two unrelated U.S. tobacco companies and their foreign subsidiaries today resolved civil and criminal FCPA charges with the SEC and DOJ.
In the criminal cases, two foreign subsidiaries of North Carolina-based Alliance One International Inc.… Continue Reading