General
What an amazing turn of events? -- Who would have predicted that the Trump Administration would take such a bold action in the name of advancing "American Competitiveness." I admit I did not see this coming -- the Trump Administration during the first term had an aggressive record of FCPA
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The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. ("GOL") to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement ("DPA") with DOJ in exchange for
General
In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase -- "reading the tea leaves." (or "tasseography," a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021,
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In the FCPA and white collar defense community, we have seen buckets and buckets of ink spilled on the coming wave of aggressive enforcement. Justice Department officials have made so many statements about the “new” approach to prosecuting white collar crime. The government moves slowly and implementing far-reaching changes
General
This was a strange year. Not just because of the continuing pandemic and economic disruption. The Biden Administration took over after an unusual and delayed transition. The apparatus of government was slow to transition. Compounding this disruption, the government had to maintain a singular focus on the pandemic. As a
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Well, it is that time again. I get to put on my Carnac the Magnificent Hat and offer my FCPA predictions for 2021. I should get a pass on my 2020 FCPA Predictions posting because no one could have anticipated the COVID-19 pandemic. Although even with the asterisk, I