Top Menu

FCPA Flash Podcast – A Conversation With Philip Urofsky Regarding 2018 FCPA Trends And Developments

Podcast Logo

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 Philip Urofsky (Shearman & Sterling and a former FCPA enforcement official at the DOJ). During the podcast, Urofsky elaborates on various issues such as jurisdiction over foreign actors and parent-subsidiary issues found in the firm’s always informative FCPA Digest. Urofsky also opines on what the FCPA enforcement landscape might look like if business organizations would put the government to its burden of proof in enforcement actions.

Continue Reading

Friday Roundup

Roundup

No jail time for Stevens, neither admit nor deny airball, Jorgensen to depart Walmart, scrutiny alert and ripple. It’s all here in the Friday roundup.

No Jail Time for Steven

Further to the randomness of FCPA sentences (see here for the prior post), former Embraer executive Colin Steven (who plead guilty to causing $1.5 million in bribe payments to be made by Embraer to a Saudi Official in connection with a $93 million sale as well as receiving approximately $130,000 in kickbacks) was recently sentenced to no jail time. (See here for coverage).

Continue Reading

SEC Co-Director Of Enforcement Peikin On International Cooperation

Peikin

Recently Steven Peikin (Co-Director of the SEC’s Enforcement Division) delivered this speech in which he talked about international cooperation and how it is “critical to the SEC’s civil law enforcement success” including the Foreign Corrupt Practices Act space.

In addition, Peikin stated that “vigorous enforcement of the FCPA remains a high priority for the SEC.”

Continue Reading

Lisa Osofsky (Director Of U.K. Serious Fraud Office) Speaks On A Variety Of Topics

osofsky

U.S. enforcement officials are not the only ones who speak at FCPA conferences hosted by for-profit conference firms. (See here). “Foreign officials” do as well.

So let’s see, the conference firms are “domestic concerns” under the FCPA, a speaking slot is a thing of value, the foreign law enforcement official is a “foreign official,” and the thing of value to the foreign official helps drive attendance to the conference firm’s paid event. But, I digress.

Recently, Lisa Osofsky (Director of the U.K. Serious Fraud Office) delivered this speech at an FCPA conference and touched upon the following topics: SFO priorities, international cooperation, corporate cooperation and integrity, and the SFO’s use of technology.

Continue Reading

Deputy AG Rosenstein On A Variety Of FCPA Issues

rosenstein

It is the end of November.

Thus, as sure as the sun rises in the east and dogs bark, our Foreign Corrupt Practices Act enforcement officials allowed themselves to be used as marketing props by a for profit conference firm to drive attendance to its paid event. (See here for how the selling of FCPA enforcement officials needs to stop).

In other words, a DOJ enforcement official spoke at ACI’s FCPA conference yesterday.

In this speech, Deputy Attorney General Rod Rosenstein talked about the rule of law, the DOJ’s no-piling on policy, the importance of individual prosecutions, and announced a tweek to DOJ policy regarding cooperation credit. Instead of requiring companies to identify every employee involved in criminal conduct, the DOJ’s new policy calls for companies to identify “every individual who was substantially involved in or responsible for the criminal conduct.”

Continue Reading

Powered by WordPress. Designed by WooThemes