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FCPA Blog Daily News

Entries in Yates Memo (23)

Monday
Jun192017

FBI Special Agent Adam Lee on FCPA probes: ‘We use all of the techniques available to us’

I spoke last Thursday with Adam S. Lee, the Special Agent in charge of the U.S. Federal Bureau of Investigation's Richmond Division.

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Tuesday
Jun132017

Richard Bistrong: I wanted to go home, the judge wanted me in jail

A few weeks ago, I read about an “exasperated federal judge” at the sentencing of Samuel Mebiame, the 43-year-old son of the former prime minister of Gabon, who was an intermediary for Och-Ziff. 

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Thursday
Jun012017

Resource Alert: How to do business during a corruption investigation

Shearman & Sterling has published a client alert a lot of us need these days -- “Transacting Business During a Corruption Investigation.”

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Monday
Dec192016

Rebecca Gantt: Looking for clues about the future of the Pilot Program

Last April, the DOJ's Criminal Division launched the one-year Pilot Program. The remaining four months of the Pilot Program promise to provide valuable information on several fronts.

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Monday
Oct312016

Brackett and Neale: Enforcement Innovations for the Post-Yates Environment

During a recent webinar sponsored by the Washington Legal Foundation, we explored the impacts intensive individual-focused criminal enforcement can have on an industry, using the recent history of criminal enforcement of food safety laws as a case study. 

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Monday
Sep192016

Mike Scher: Three questions for Wells Fargo

Employees at Wells Fargo opened about two million deposit and credit card accounts that customers didn't authorize. Why? To earn incentive compensation for new accounts.

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Monday
Aug222016

When It Absolutely, Positively Has to Be Indicted Overnight: How to Prevent Future Debacles Like the FedEx Prosecution

Against the backdrop of years of unprecedented monetary penalties imposed through DOJ civil settlements and deferred prosecution agreements with financial institutions embroiled in the 2008 financial meltdown, the DOJ came under withering criticism for perceptibly treating scrutinized corporations simply as cash cows rather than addressing the actual criminal conduct of the corporations and their executives.

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Thursday
Jun232016

The Analogic Settlement: What's behind the issue of cooperation credit?

As reported by the FCPA Blog Tuesday, the SEC and DOJ entered into parallel resolutions with Analogic Corporation and Analogic's wholly-owned Danish subsidiary BK Medical ApS in connection with violations of the books and records and accounting controls provisions of the FCPA.

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Wednesday
Jun012016

U.S. Chamber: ‘Yates Memo could lead to more enforcement abuses’

The Institute for Legal Reform -- part of the U.S. Chamber of Commerce -- issued a paper last week with a harsh review of the Yates Memo, also known as the DOJ's Individual Accountability Policy

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Wednesday
May182016

Joseph Spinelli: Yes, the Yates Memo is a watershed event

Career prosecutor and current Deputy AG Sally Yates authored one the most important DOJ policy papers in decades -- the Yates Memo, also known as the DOJ's Individual Accountability Policy.

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Wednesday
May112016

Yates Speaks: Prosecuting individuals is really hard, so companies need to come clean

Deputy Attorney General Sally Q. Yates spoke Tuesday to the New York City Bar Association White Collar Crime Conference. Her topic? That's right. The Yates Memo, more formally known as the DOJ's Individual Accountability Policy.

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Thursday
Apr072016

The DOJ Pilot Program: Financial considerations for both companies and their executives

The DOJ Fraud Section’s recently released FCPA Enforcement Plan and Guidance outlines a novel one-year pilot program for corporate self-reporting and cooperation, with specific fine reduction incentives.

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