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Editors

Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Elizabeth K. Spahn Editor Emeritus

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

Monday
Sep182017

Richard Bistrong finds his flow

In Finding Flow, author Mihaly Csikszentmihalyi said “flow tends to occur when a person’s skills are fully involved in overcoming a challenge that is just about manageable.” 

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Monday
Sep182017

Job: Director, Anti-Bribery/Corruption Compliance Officer

Job Title: Director, Anti-Bribery/Corruption Compliance Officer

Employer: Merck & Co., Inc

Location: Gwynedd, Pennsylvania USA

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Friday
Sep152017

Resource Alert: IBA Local Legislation Library (It's free!)

The International Bar Association has added to its website a more complete library of local anti-corruption legislation, and it's very cool.

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Thursday
Sep142017

Now there's a scoreboard of Odebrecht bribes

Just how widespread was Odebrecht's bribery?

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Thursday
Sep142017

Andy Spalding: The Pilot Program addresses three criticisms, but raises a new one

The Pilot Program is best understood as the DOJ’s response to three distinct lines of public commentary on FCPA enforcement. The Department should be commended for responding to this commentary -- indeed, for even listening to it in the first place. And the responses have, in my view, largely been smart and fair. But it’s created a new difficulty. Fortunately, that difficulty is easily addressed.

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Wednesday
Sep132017

Life Science Alert: China judicial interpretation criminalizes submission of false clinical trial information

A recent judicial interpretation issued by China’s top judicial and prosecutorial bodies now criminalizes submitting falsified nonclinical study or clinical study reports and related materials. This could affect life sciences companies and contract research organizations operating in China.

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Wednesday
Sep132017

U.S. commitment to enforcing the FCPA – A discussion with Philip Urofsky

Last week I spoke with Philip Urofsky, a partner at Shearman and Sterling, and a former federal prosecutor, responsible for investigating and advising on matters involving potential violations of the Foreign Corrupt Practices Act.

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Tuesday
Sep122017

Practice Note: Dealing with allegations of Gross Human Rights Abuse

As noted in the prior post, there are no formal legal defenses available when a company violates the Gross Human Rights Abuse provisions of the Criminal Finances Act. How, then, should companies deal with allegations that they've committed violations?

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Tuesday
Sep122017

Andy Spalding: ‘Constructive criticism’ actually has two elements

Law schools have not historically excelled at cultivating the art of constructive criticism. So many of us once were, and some still are, people who believe that success is a zero-sum game; that the only way to build oneself up is to tear another down; that doing good is far less important than doing well; that another’s contribution is inherently a threat to my own self-worth.

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Monday
Sep112017

New disclosure shows spreading Eni bribery probe

An SEC filing last week by a giant Italian oil company showed how a corruption investigation has grown, starting three years ago in Nigeria but spreading now to include Algeria, Congo, Kazakhstan and Kuwait.

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Monday
Sep112017

Carlson and Ma: Revised China commercial bribery rules would broaden offenses and raise penalties

Last week China released for public comment new draft amendments to the Anti-Unfair Competition Law (AUCL), which governs commercial bribery and other acts of unfair competition. 

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Monday
Sep112017

Andy Spalding: The Pilot Program as declination policy

We’ll spend a number of posts this month explaining what is good about the Pilot Program and what may be better. The last post explained the four (not three) requirements the Program establishes -- voluntary disclosure, cooperation, remediation, and disgorgement -- and how some of those terms have been carefully (re)defined. Here, let’s talk about what’s in it for the defendant.

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