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Deputy Assistant Attorney General Matthew Miner On ….

miner

Recently Deputy Assistant Attorney General Matthew Miner delivered this speech at an American Bar Association event in Prague.

During the speech, Miner touched upon international cooperation; the DOJ’s so-called “no piling on” policy; the DOJ’s “Evaluation of Corporate Compliance Programs” guidance document; gathering evidence in foreign countries; voluntary disclosure, cooperation and so-called declinations; and enforcement actions against foreign companies.

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“Frankly, If You Bring In A Couple Billion Dollars A Year, You Just Keep On Going,” And Other Musings From Former FCPA Prosecutors

listeningin

This Trace International Bribe, Swindle or Steal podcast is a recording of a recent panel discussion between former FCPA prosecutors Charles Duross (DOJ), Nat Edmonds (DOJ) and Richard Grime (SEC).

It is an informative listen on several levels including voluntary disclosure and international cooperation and set forth below are some of the more candid comments from the former FCPA prosecutors.

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Let’s Analyze This For A Minute

846-05647896
© ClassicStock / Masterfile
Model Release: Yes
Property Release: No
1960s MAN THINKING HAND PENCIL ON CHIN WEARING EYEGLASSES SERIOUS EXPRESSION

This recent Wall Street Journal Risk & Compliance Journal post by an individual new to the Foreign Corrupt Practices Act space reads in full:

“A U.S. Justice Department program that incentivizes companies to self-report foreign corruption is making headway as prosecutors look for ways to hold individuals accountable for wrongdoing, according to an official in the department’s Foreign Corrupt Practices Act unit.”

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DOJ FCPA Enforcement – 2018 Year In Review

Justice Dept

This previous post highlighted various corporate Foreign Corrupt Practices Act enforcement statistics from 2018 and this post goes in-depth into various facts and figures relevant to DOJ FCPA enforcement in 2018. (See here for a similar post from 2017, here for a similar post from 2016, here for a similar post from 2015, here for a similar post from 2014, here for a similar post from 2013, here for a similar post from 2012, here for a similar post from 2011, and here from 2010).

Settlement Amounts and Specifics

In 2018, the DOJ brought 8 corporate FCPA enforcement actions.

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Principal Deputy Assistant AG Cronan Delivers Yet Another FCPA Speech

Cronan

On October 18th, Principal Deputy Assistant Attorney General John Cronan delivered a speech in Brazil at an event hosted by a for-profit business that generally charges people to attend (see here for the prior post). On October 25th, Cronan delivered another speech in Washington, D.C. at another event hosted by the same for-profit business.

Why DOJ (and SEC) officials allows themselves to be used in such a way by profit-seeking businesses to drive attendance to their events is beyond me. (See prior posts here and here, among many others, for why the selling of FCPA enforcement attorneys needs to stop).

Ethics aside, in his speech Cronan talked about the DOJ’s priorities with respect to corporate enforcement, what the DOJ expects “from companies who choose to voluntarily self-disclose misconduct and seek to cooperate with law enforcement,” and the DOJ’s “commitment to reaching fair and equitable resolutions, including through the principles reflected in the Criminal Division’s policy with respect to monitors.”

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