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Friday Roundup


Checking in on the Hoskins appeal, checking in up north, checking in across the pond, for the younger generation, if that would happen in a company, and another one dismissed. It’s all here in the Friday roundup.

But first, if you got your FCPA from FCPA Professor in 2016, please consider a donation to help defray the yearly costs of running this free public website.

Checking In on the Hoskins Appeal

This previous post highlighted how U.S. District Court Judge Janet Bond Arterton (D.Conn) significantly trimmed the DOJ’s criminal FCPA enforcement action against Lawrence Hoskins. Unhappy with the decision, the DOJ filed a motion for reconsideration which Judge Arterton denied (see here).

The DOJ appealed to the Second Circuit and this previous post highlighted the DOJ’s opening brief. Recently Hoskins filed this response which states in pertinent part.

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Andrew Weissmann On The FCPA – It Is “Very Easy For The People At The DOJ And SEC To Basically Impose A Tax For Doing Business” In Certain Countries


One of more concerning aspects of the Foreign Corrupt Practices Act landscape is the extent to which current FCPA enforcement officials have articulated seemingly contradictory positions prior to or after their stint at the DOJ or SEC. For instance, see prior posts here (“A Former Enforcement Official Is Likely to Say (Or Has Already Said) the Same Thing”) and here (“In the FCPA Space, Who Speaks for Whom?”).

FCPA Professor was the first to highlight the seeming irony when vocal FCPA enforcement critic and reform advocate Andrew Weissmann was selected to head the DOJ’s fraud section in January 2015 and how Weissmann should have stayed true to his former self when unveiling the DOJ’s “FCPA Pilot Program” in April 2016.

Weissmann’s prior positions on the FCPA are nicely captured in a 2010 panel event in which he speaks at great length regarding various aspects of the FCPA.

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Friday Roundup


From the dockets, you gotta be kidding me, it’s a numbers game, former DOJ FCPA Unit Chief Duross on …, scrutiny updates, a foreign official teaser, a bracket of a different kind, and an event notice. It’s all here in the Friday Roundup.

From The Dockets

Two developments in DOJ FCPA individual actions.

One the DOJ apparently wants you to do know about because it issued a press release, the other apparently not because there was no press release.

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Friday Roundup


Not something you see everyday, Yates Memo related, quotable, scrutiny alerts and updates, and for the reading stack. It’s all here in the Friday roundup.

Not Something You See Everyday

It’s not everyday that you see a director of a publicly-traded company publicly resign because the director thinks the company is engaged in improper conduct including FCPA violations.

But that is just what Michael Moss, until recently a director of Malvern Bancorp, did.

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FCPA Flash – A Conversation With Paul Pelletier

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The new FCPA Professor contains a new feature – the FCPA Flash podcast.

The goal of FCPA Flash is to provide, 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 the written posts on FCPA Professor.

This FCPA Flash episode is a conversation with  Paul Pellletier, a former Principal Deputy Chief of the DOJ’s fraud section and currently a member of Mintz Levin. Pelletier has written some excellent recent pieces on the DOJ’s FCPA enforcement program (see here and here) and in the podcast he discusses the long time periods often associated with FCPA inquiries, FCPA investigative costs, and how the DOJ can best allocate its resources to fight bribery.

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