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Potpourri
[To the best of my recollection, my first introduction to the word “potpourri” was in watching Jeopardy which I was very fond of as a teenager and young adult. Rest in peace Alex Trebek] Lingo Daniel...
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Contrary To The Narrative
There are certain narratives in the Foreign Corrupt Practices Act space – while theoretically possible – are rarely, if ever, found in actual FCPA enforcement actions. For instance, all probably...
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In Resolving The Berko Enforcement Action, What About Liu?
As highlighted in this prior post, in June 2020 the Supreme Court concluded in Liu v. SEC that “a disgorgement award that does not exceed a wrongdoer’s net profits and is awarded for victims is...
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Amec Foster Wheeler / John Wood Group Enforcement Actions – What Actually Was...
Previous posts here, here, here and here highlighted various aspects of the recent U.S. and U.K. enforcement actions against Amec Foster Wheeler / John Wood Group. The enforcement actions included: (i)...
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Friday Roundup
Where is the outrage now, Odebrecht related, and for the people. It’s all here in the Friday roundup. Where Is The Outrage Now? In 2016 the Obama Justice Department invented another way to resolve an...
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Victims … But No Victims
“Bribery is not a victimless crime.” It is a narrative in DOJ FCPA talking points (see here for instance). If bribery is not a victimless crime, then why do FCPA fines and penalties nearly always...
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Medical Services Company To File Restitution Claim In Connection With...
As highlighted here, in May 2022 Glencore (a commodities company incorporated in the United Kingdom and headquartered in Switzerland) resolved a net $443 million FCPA enforcement action. According to...
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Friday Roundup
Settled, not a victim, and monitor reports. It’s all here in the Friday roundup. Settled As highlighted in this prior post, in 2021 Shaquala Williams (a former employee of JPMorgan in New York city)...
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Glencore Acknowledges A Victim, But Disputes The Amount Of Restitution Owed
As highlighted in this prior post, in connection with the May 2022 Glencore FCPA enforcement action, the majority owners of Crusader Health (Ian and Laureth Hagen) petitioned the court in the...
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Am I A Victim?
As highlighted in this recent DOJ release, the CEO of a multinational corporation was criminally charged for giving, offering, and promising money to a Marine Liaison Officer for the U.S. Navy’s Fifth...
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