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In Post-Trial Motions, Baptiste Seeks Judgment Of Acquittal Or New Trial...

As highlighted in this previous post, in 2017 (in connection with an undercover string) the DOJ unsealed criminal charges against Joseph Baptiste (a retired U.S. Army Colonel, practicing dentist, and...

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DOJ’s Kahn Answers The PPE FCPA Hypothetical

One common Foreign Corrupt Practices Act hypothetical that has been repeated often over the last couple of months sort of goes like this. The current COVID-19 crisis presents increased FCPA risks...

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Regarding Extortion …

As highlighted in this prior post, the FCPA Blog recently posed the silly question “are agents ever ‘legal’ under the FCPA?” Now the FCPA Blog is asking why “nobody talks about the FCPA extortion...

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In A Highly Unusual Development, DOJ Brings A $19.6 Million Enforcement...

DOJ and SEC Foreign Corrupt Practices Act enforcement actions against issuers based on the same core conduct are relatively common. However, such actions are nearly always coordinated and announced on...

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Ransom Payments And Corrupt Intent

Recently, the CEO of Colonial Pipeline Co. acknowledged that he authorized a $4.4 million ransom payment to the perpetrators of the recent cyberattack on the company’s distribution system. CEO Joseph...

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California Court Dismisses Bribery Charges Against Former Apple Inc....

California Penal Code Section 67 is similar to the anti-bribery provisions of the Foreign Corrupt Practices Act in that it states: ““Every person who gives or offers any bribe to any executive officer...

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Recent DOJ Opinion Procedure Release Reads Like A Hollywood Script

The Foreign Corrupt Practices Act when enacted directed the DOJ Attorney General to establish a procedure to provide responses to specific inquiries by those subject to the FCPA concerning conformance...

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A Closer Look At The Ng Jury Instructions

Foreign Corrupt Practices Act jury trials are rare. Therefore, FCPA jury instructions are also rare. Highlighted below are certain portions of the jury instructions from the recent trial of Roger Ng (a...

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Issues To Consider From The Stericycle Enforcement Action

This previous post highlighted the recent net $59 million Foreign Corrupt Practices Act enforcement action against Stericycle (an Illinois based medical waste disposal company) for conduct in Brazil,...

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Checking In On The Wakil Enforcement Action

As highlighted in this prior post, in August 2021 the DOJ announced that Naman Wakil, a Syrian national and U.S. lawful permanent resident, was “arrested in Miami on charges related to his alleged role...

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