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
An FCPA anti-bribery offense requires five essential elements: (1) Corruptly (2) paying or promising to pay (3) anything of value (4) to a foreign official (5) for the purpose of obtaining or retaining business or securing any improper advantage.… Continue Reading
While we have understandably been distracted by the challenges of 2020 – from serious concerns about our health and the well-being of our loved ones to not-so-serious concerns of how we look on video conferences – things in the FCPA world have been humming along.… Continue Reading
The DOJ and SEC published the Second Edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act Friday, updating for the first time the best government-produced FCPA guidance.… Continue Reading
A former Alstom sales manager in the United States who helped the DOJ prosecute other company executives and testified at the trial of one of them was sentenced Monday to two years of supervised release.… Continue Reading
A federal judge Wednesday partially acquitted the former Alstom S.A. executive convicted by a federal jury in November of bribing officials in Indonesia, ruling that prosecutors had failed to prove he violated the Foreign Corrupt Practices Act by acting as an agent of Alstom’s Connecticut subsidiary.… Continue Reading
It made sense for Lawrence Hoskins to challenge whether the Foreign Corrupt Practices Act could apply to him. He had worked for Alstom SA, a French company, in Paris. He carried a UK passport and said he never set foot in the United States.… Continue Reading
A former Alstom SA executive who carried a UK passport, worked in France, and said he never set foot in the United States, was convicted Friday by a federal jury on 11 of 12 counts for his part in a scheme to bribe government officials in Indonesia.… Continue Reading
Federal District Court Judge Janet Bond ArtertonA federal district court ruled Monday that Lawrence Hoskins, the British national who worked for Alstom, will have to face a trial for violating the Foreign Corrupt Practices Act and related offenses.… Continue Reading
The corporate compliance community glimpsed a rare event in August: a federal court decision, U.S. v. Hoskins, tried to define the limits of individual liability under the Foreign Corrupt Practices Act.… Continue Reading
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
A federal appeals court ruled Friday that a non-resident foreign national cannot be charged with conspiracy to violate the Foreign Corrupt Practices Act or with aiding and abetting a violation of the FCPA, 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
On March 16, the U.S. District Court for the District of Connecticut affirmed its earlier ruling that a non-resident foreign national cannot be charged with conspiracy to violate the Foreign Corrupt Practices Act or with aiding and abetting a violation of the FCPA, 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
