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A Look Back At Robert Allen Stanford And The FCPA

stanford

Samuel Bankman-Fried of course is presumed innocent of the criminal charges against him (including the recent Foreign Corrupt Practices Act charge – see here for the prior post) until proven otherwise by the government or a plea by the defendant.

As detailed in the prior post, the FCPA charge against Bankman-Fried focuses on an alleged bribe to Chinese officials to unfreeze certain trading accounts containing over $1 billion in cryptocurrency – which had been frozen by Chinese authorities – so that Bankman-Fried and others could use the assets to fund additional trading activity.

In other words, the DOJ alleges, Bankman-Fried conspired to violate the FCPA to help facilitate the overall financial fraud schemes he allegedly engaged in.

As detailed below, this is not the first time the FCPA was lurking in the background of a high-profile financial fraud case.

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This Week On FCPA Professor

ThisWeekPost

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

This post takes a closer look at the “factual basis for breach” in the Ericsson matter.

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This Week On FCPA Professor

ThisWeekPost

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

As highlighted here, Corsa Coal agreed to pay $1.2 million in a “declination with disgorgement” enforcement action, but it could have been worse as the DOJ relieved the company of the remaining $31.5 million disgorgement amount based on inability to pay.

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This Week On FCPA Professor

ThisWeekPost

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

Assistant Attorney General Kenneth Polite called prosecutors “community problem-solvers” and announced yet additional changes to DOJ policy. See here.

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Assistant AG Polite Calls Prosecutors “Community Problem-Solvers” – Announces Yet Additional Changes To DOJ Policy

Polite

Last week, Kenneth Polite (DOJ Assistant Attorney General -Criminal Division) gave this speech in which he called prosecutors “community problem-solvers” and announced (yet additional) changes to DOJ policy.

Specifically, Polite announced “significant changes” to how the DOJ “consider[s] a corporation’s approach to the use of personal devices as well as various communications platforms and messaging applications, including those offering ephemeral messaging.”

In addition, Polite described how the DOJ has “updated its policies concerning corporate compensation systems” and issued a “revised memorandum on the selection of monitors in Criminal Division matters” including that “any submission of a monitor candidate by the company and selection of a monitor candidate by the Criminal Division should be made in keeping with the department’s commitment to diversity, equity, and inclusion.”

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