FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
The decision highlights the US government’s focus on effective compliance programs.
The US Department of Justice (DOJ) is creating a new compliance counsel position in the Criminal Division to assess the effectiveness of...more
On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more
The civil money penalty was surprising for two reasons: first, that FinCEN would investigate and fine a casino unfamiliar even to analysts who cover the gaming industry, on an island chain few knew existed; and second, for...more
Last week, the DOJ announced its first corporate enforcement action under the Foreign Corrupt Practice Act (“FCPA”) for 2015. IAP World Services, Inc., a Florida-based defense and government contractor, agreed to pay $7.1...more
IAP Worldwide Services Inc., a Virginia based facilities management firm, entered into a non-prosecution agreement with the Department of Justice and agreed to pay a $7.1 million penalty to resolve FCPA charges. A vice...more
On June 16, the DOJ entered into a non-prosecution agreement with a Florida-based defense and government contracting company to resolve allegations that it conspired to bribe Kuwaiti officials for the purpose of securing a...more
Okay, everyone take out their tea leaves and let’s get started on the IAP corruption case – DOJ announced a Non-Prosecution Agreement with IAP Worldwide Services and the criminal plea of a former executive who funneled bribes...more
John David Crow died Wednesday. Until Johnny Football, he was the only football player from Texas A&M University to win the Heisman Trophy. He played under the legendary Paul ‘Bear’ Bryant at A&M and for all of Bryant’s...more
On this day, 203 years ago, President James Madison signed a Declaration of War against Great Britain inaugurating the War of 1812. The cause of the war was multi-faceted; the formal reason given was the British impressment...more
Today the Justice Department announced that Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB), have reached resolutions under the department’s Swiss Bank Program. With today’s...more
On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more
DOJ has developed a new and innovative model for criminal prosecution of corporations. The jury is still out on whether this model is the best use of public resources.
DOJ frequently touts its successes based on...more
The Department of Justice has released the signed Non-Prosecution Agreement NPA) with Swiss bank BSI SA. The Non-Prosecution Agreement is likely the precursor to enhanced enforcement efforts by the DOJ and IRS against those...more
The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad.
The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more
On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...more
On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure...more
BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more
Today the Justice Department announced that BSI SA of Lugano, Switzerland, one of the 10 largest private banks in Switzerland, is the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program....more
The controversy surrounding Deferred Prosecution Agreements (“DPAs”) and Non- Prosecution Agreements (“NPAs”) continues to boil.
In response to continuing criticism that the Justice Department is using DPAs and NPAs to...more
I will use Agatha Christie’s short story The Companion as the introduction to today’s blog post. This story, related by one of the Tuesday story-telling group of detective aficionados, Dr. Lloyd, and is about two people who...more
The Department of Justice (DOJ) still faces criticism over its Foreign Corrupt Practices Act (FCPA) enforcement strategy. Some decry that it is too aggressive, that the DOJ has moved into waters Congress never intended the...more
In this episode, the FCPA Professor and myself continue our exploration of DPAs and NPAs through the recent book review of Judge Rakoff and rejection of a DPAs by Judge Leon in an export control case. ...more
On the accountability and punishment front, three trends bear watching:
1) Deferred Prosecution Agreements (DPAs)
DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more
As readers of this blog know the FCPA Professor and I usually look at the same Foreign Corrupt Practices Act (FCPA) enforcement action, item or remark and see different things. Sometimes we even hear the same thing and come...more
The Future of the Department of Justice’s High Visibility Offshore Tax Evasion Initiative.
On August 29, 2013, the U.S. Department of Justice (“DOJ”) Tax Division announced the Program for Non-Prosecution Agreements...more
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