News & Analysis as of


The Aviation Industry and Corruption

by Michael Volkov on

DOJ and the SEC have quietly (or maybe not so quietly) set an enforcement tone in the aviation industry. When you look over the last few years, we have several enforcement actions either pending or resolved involving the...more

The End of an Era and the End of Facilitation Payments?

by Thomas Fox on

Two famous New Yorkers died this week. Both spoke to not only to the glamour of the Big Apple, but the city’s once undisputed crown as the cultural mecca of the US. They were Allie Sherman and Bess Myerson....more

The FCPA Year in Review: Twist and Shout (Part I of II)

by Michael Volkov on

We all like annual reviews and predictions for the upcoming year – it is a New Year’s rite of passage and one that brings perspective and a sense of order to our otherwise chaotic lives....more

The Long Arm of the FCPA: Former BizJet CEO Arrested in Amsterdam, Pleads Guilty in Oklahoma

by Morrison & Foerster LLP on

On July 24, 2014, the Department of Justice (DOJ) announced that Bernd Kowalewski, the former president and chief executive officer of BizJet International Sales and Support Inc. (“BizJet”), pleaded guilty to conspiracy to...more

Board Of Directors Reform: Adopting A New Model For Board Members

by Michael Volkov on

It is easy to tie FCPA violations to corporate governance performance. Sometimes the tie is strong – sometimes a little more attenuated. The BIzJet case from last year underscored the importance of proper board...more

Individual FCPA Enforcement Actions In 2013

by Thomas Fox on

This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more

The FCPA Person Of The Year – The Prosecutor

by Michael Volkov on

To continue a “tradition” on Corruption Crime and Compliance, I like to end the year with recognition of the “person of the year,” referring to the institution which has had the most impact in the enforcement and compliance...more

FCPA Prosecutions Against Individuals? Check Out April

by Thomas Fox on

One of the oft-heard criticisms of the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) is the lack of individual prosecutions under the Foreign Corrupt Practices Act (FCPA). That may well be on its...more

What’s The Message From BizJet? Self-Disclose And Cooperate

by Thomas Fox on

Over the past week there has been a plethora of Foreign Corrupt Practices Act (FCPA) enforcement actions released. One group was the four enforcement actions involving individuals concerning BizJet. While I cannot say that...more

Lessons Learned from the BizJet Executives FCPA Enforcement Actions

by Thomas Fox on

BizJet self-disclosed to the DOJ, engaged in what the DOJ termed “extraordinary cooperation” and remediated the people and conduct in question. Further, DuBois and Uhl not only offered themselves up but actively worked with...more

The BizJet Case: The Drama Unfolds

by Michael Volkov on

Talk about a way to start off FCPA enforcement in 2013. The Department of Justice has sent an emphatic message: Just when you think things are slowing down, they come out and surprise you....more

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