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Editors

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Harry Cassin
Publisher and Editor

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Andy Spalding
Senior Editor

Jessica Tillipman FCPA Blog

Jessica Tillipman
Senior Editor

WILLIAM B.F. STEINMAN

Bill Steinman
Senior Editor

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Richard L. Cassin
Editor at Large

Elizabeth K. Spahn

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington

Cody Worthington
Contributing Editor

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Julie DiMauro
Contributing Editor

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Thomas Fox
Contributing Editor

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Marc Alain Bohn
Contributing Editor

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Bill Waite
Contributing Editor

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Shruti J. Shah
Contributing Editor

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Russell A. Stamets
Contributing Editor

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Richard Bistrong
Contributing Editor

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Eric Carlson
Contributing Editor

Posts Tagged: Victims Rights

We support using BNP penalties for victim restitution

Aaron Bornstein and Andy Spalding May 5, 2015

The recently announced BNP sanctions settlement is remarkable in so many ways: the behavior is outrageous, the $9 billion criminal penalty is record-setting, and 13 employees were terminated. However, the most interesting part of the story may be the idea that the DOJ is exploring ways to use the forfeited funds to compensate individuals who may have been harmed by the sanctioned regimes of Sudan, Iran and Cuba.… Continue Reading

The BOTA Foundation explained (Part Nine): How effective was BOTA?

Aaron Bornstein April 22, 2015

The BOTA Foundation surpassed most of the expectations that its founders had for it. BOTA was able to efficiently and effectively return more than $115 million (the original $84 million associated with corruption plus accrued interest frozen Pictet and Cie Swiss bank account) to poor children, youth and their families.… Continue Reading

The BOTA Foundation explained (Part Eight): BOTA’s Grants and Scholarship Program

Aaron Bornstein April 21, 2015

BOTA had three programs, with its largest, the Conditional Cash Transfer (CCT) Program, briefly explained in the previous post. Funds from the Pictet and Cie bank account associated with James Giffen and President Nazarbayev were used in two other ways to help poor children and youth in Kazakhstan: via a NGO grants program, called the Social Service Program (SSP), and through a scholarship program known as the Tuition Assistance Program (TAP).   … Continue Reading

The BOTA Foundation explained (Part Six): How was BOTA set up?

Aaron Bornstein April 15, 2015

BOTA was the first foundation ever established as a result of an FCPA case, and the question explored in this post is how it was set up.

There are two important facts to keep in mind as background: Kazakhstan was in a disadvantaged position in the negotiations (it needed BOTA to solve a political problem discussed in Part Three); and, the U.S.… Continue Reading

It’s Simple: The Nigerian Money is the Nigerians’ Money

Andy Spalding March 20, 2014

Friends of the FCPA Blog — Sandy Sierck and Nick Diamond, who represent the Socio-Economic Rights and Accountability Project in Nigeria — have another good idea. For years, SERAP has been petitioning the DOJ and SEC to return enforcement revenues to the real victims of overseas corruption: the citizens of the corrupt governments.… Continue Reading

What does it take to change the world?

Richard L. Cassin December 5, 2013

Professor Elizabeth Spahn spoke for victims of bribery before most of us had discovered the topic. She has defended compliance as pro-business and condemned bribes for destroying capitalism. More eloquently than anyone else, she has stood for the idea — once derided and now embraced — that compliance and enforcement can change the world and help people live better lives.… Continue Reading