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FCPA Flash Podcast – A Conversation With Lucinda Low

FCPA Flash

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Lucinda Low (Steptoe & Johnson). During the podcast, the experienced FCPA practitioner: (i) provides an assessment of 2019 FCPA enforcement; (ii) discusses the long time periods associated with FCPA scrutiny; (iii) explores the broadness of FCPA enforcement specifically the FCPA’s accounting provisions; and (iv) highlights why she believes the FCPA should be amended to include a compliance defense.

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Deputy AG Rosenstein On ….

rosenstein

Recently outgoing Deputy Attorney General Rod Rosenstein delivered this speech to a university audience. Like many of Rosenstein’s prior speeches highlighted on these pages, the speech was a pleasure to read for its general advice.

For instance, Rosenstein stated: “Today, you are relentlessly bombarded with information, much of it of unknown reliability. The internet lets people share their most ignorant thoughts. Many news stories rely on anonymous sources, without providing details to assess their credibility and bias. Some critics worry that our society will be unable to distinguish fact from opinion, and truth from fiction.”

Perhaps Rosenstein was talking about certain FCPA commentary? (See here, here and here for instance).

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DOJ’s Cronan On The “Importance Of Law Enforcement And Private Industry Working Together” (With Rebuttal Points)

workingtogether

Yesterday, DOJ Principal Deputy Assistant Attorney General John Cronan delivered this speech “about the importance of law enforcement and private industry working together in pursuit of common, shared objectives.”

Cronan’s speech touched upon a number of topics including the DOJ’s FCPA Corporate Enforcement Policy, so-called declinations, transparency in law enforcement, and merger and acquisition issues. This post excerpts the speech and provides various rebuttal points.

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Deputy AG Rosenstein On …

rosenstein

Last Thursday was a big speech day for Deputy Attorney General Rod Rosenstein. In addition to announcing a new non-binding DOJ policy on “coordination of corporate resolution penalties,” (see here and here for prior posts) Rosenstein also appeared at an FCPA conference and delivered this speech (continuing the disgraceful practice of for-profit conference firms using our public officials to drive attendance to their paid events).

Rosenstein’s speech was in part duplicative of his earlier “piling on” speech, but this post highlights Rosenstein’s general statements on the FCPA, foreign law enforcement cooperation, and the DOJ’s recent so-called declination.

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Friday Roundup

Roundup

Motion to dismiss filed, guilty plea, role reversal, adequate procedures, for the reading stack, and viewing suggestion. It’s all here in the Friday roundup.

Motion to Dismiss Filed

As highlighted in this prior post, in November 2017 the DOJ announced that Chi Ping Patrick Ho (of Hong Kong, China) and Cheikh Gadio (of Senegal) were criminally charged with conspiring to violate the Foreign Corrupt Practices Act, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.

Earlier this week, Ho filed this motion to dismiss certain of the FCPA and money laundering charges.

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