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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

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FCPA Blog Daily News

Entries in Disgorgement (51)

Monday
Sep252017

Telia also tops our new Top Ten Disgorgements list

Telia Company AB's $965.6 million settlement Thursday included disgorgement to the SEC of $457 million, the biggest disgorgement ever ordered in an FCPA enforcement action.

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Thursday
Sep212017

Telia disgorges $457 million to SEC, agrees to $965 million in total penalties for FCPA offenses

The SEC said in an enforcement order Thursday that Sweden's Telia Company AB will disgorge $457 million to resolve FCPA violations in Uzbekistan.

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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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Friday
Sep082017

Hey, declinations WITHOUT disgorgement are still popular too

There have been seven declinations under the DOJ's Pilot Program since it launched in April 2016. The most recent one was in June this year involving CDM Smith Inc.

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Thursday
Sep072017

Karen E. Woody: Declinations with disgorgement make me queasy. Here's why

As readers of the FCPA Blog are aware, the Pilot Program requires voluntary self-disclosure and cooperation with the government in order to be eligible for a declination from the DOJ.

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Thursday
Aug312017

Practice Alert: Implicit warnings in the DOJ’s declinations with disgorgement

Since the DOJ launched the Pilot Program in April 2016 to encourage companies to self-report FCPA violations and cooperate with the feds, the DOJ has published seven declination letters addressed to companies under investigation.

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Friday
Jun302017

Boston contractor pays $4 million for declination with disgorgement

Privately held CDM Smith Inc. entered into a declination with disgorgement Thursday with the Justice Department to resolve FCPA offenses in India.

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Tuesday
Jun202017

Linde pays $11 million for declination with disgorgement

Two American units of Germany's Linde Group received a declination with disgorgement from the DOJ Friday for FCPA offenses in the Republic of Georgia.

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Wednesday
Jun072017

Marc Alain Bohn: After Kokesh, new pressure on SEC to settle faster

The U.S. Supreme Court issued its highly anticipated opinion in Kokesh v. SEC Monday, unanimously holding that the SEC’s use of disgorgement operates as a penalty under federal law and is therefore not freed from the five-year statute of limitations.

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Tuesday
Jun062017

Supreme Court limits SEC disgorgement power

The U.S. Supreme Court Monday ruled 9-0 to limit the Securities and Exchange Commission's legal authority to recover ill-gotten profits from defendants.

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Friday
Mar102017

DOJ will keep Pilot Program after April expiry during evaluation

A DOJ official said Friday the Pilot Program won't expire on April 5 but will continue while the agency evaluates how the program has worked and whether it should be extended or changed.

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Tuesday
Jan172017

Chilean chemical company pays $30.5 million for FCPA violations

Sociedad Química y Minera de Chile SA agreed Friday to pay $30.5 million to resolve criminal and civil Foreign Corrupt Practices Act charges that it bribed Chilean politicians to influence government policies and plans.

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