The Giffen Gaffe
Perhaps one day the true story will be told about the DOJ’s prosecution of James Giffen. I don’t pretend to know what happened behind the scene other than to know that something significant occurred...
View ArticleOutlining Bourke’s Appeal
The DOJ recently filed its reply brief (here) in Frederic Bourke’s appeal. A prior post (here) summarized the FCPA related issues in Bourke’s brief and this post summarizes the DOJ’s reply brief. The...
View ArticleAnother Stumble For The DOJ In The Kozeny Affair
The DOJ continues to encounter problems in some of its signature FCPA prosecutions. Earlier this month, it was the Giffen Gaffe (see here). Last fall, U.S. District Court Judge Shira Scheindin...
View ArticleJudge (Again) Significantly Rejects DOJ’s Recommendations In Sentencing Nexus...
As noted in this DOJ release, last week several defendants in the Nexus Technologies enforcement action (see here for prior posts) were sentenced. Because many media sources merely regurgitate DOJ...
View ArticleSecond Circuit Affirms Bourke’s Conviction
Earlier today the Second Circuit Court of Appeals issued a decision (here) affirming Frederic Bourke’s 2009 conviction of conspiring to violate the FCPA and the Travel Act and of making false...
View ArticlePotpourri
Neither Admit Nor Deny Headed to Second Circuit It is not an FCPA enforcement action, but Judge Rakoff’s recent rejection of the SEC’s neither admit nor deny settlement policy in the Citigroup case...
View ArticleFriday Roundup
Two years ago today, you just can’t make this stuff up, no new trial for Bourke, more offensive use of the FCPA, and ICE is not melting away. It’s all here in the Friday roundup. Two Years Ago Today...
View ArticleSupreme Court Declines To Hear Bourke Case
It began in 2005 with this indictment against Frederic Bourke and others. Since then, the case against has had several twists and turns including dismissal of FCPA substantive charges on statute of...
View ArticleFriday Roundup
Enforcement agency speeches, “foreign official” delay, and for reading stack. It’s all here in the Friday roundup. Enforcement Agency Speeches This prior post detailed comments by Mary Jo White prior...
View ArticleRe-Scripting The Bourke Case
Frederic Bourke, “another whistleblower put in prison by the Obama administration.” So begins this recent lengthy depiction of the Bourke case on Democracy Now. Over the course of the approximate 45...
View ArticleFriday Roundup
Looking for talent – got talent, FBI announcement, Bourke related, to FCPA Inc., and for the reading stack. It’s all here in the Friday Roundup. Looking for FCPA Talent? Got Talent If your firm or...
View ArticleSecond Circuit Affirms Bourke’s Conviction
Earlier today the Second Circuit Court of Appeals issued a decision (here) affirming Frederic Bourke’s 2009 conviction of conspiring to violate the FCPA and the Travel Act and of making false...
View ArticlePotpourri
Neither Admit Nor Deny Headed to Second Circuit It is not an FCPA enforcement action, but Judge Rakoff’s recent rejection of the SEC’s neither admit nor deny settlement policy in the Citigroup case...
View ArticleFriday Roundup
Two years ago today, you just can’t make this stuff up, no new trial for Bourke, more offensive use of the FCPA, and ICE is not melting away. It’s all here in the Friday roundup. Two Years Ago Today...
View ArticleSupreme Court Declines To Hear Bourke Case
It began in 2005 with this indictment against Frederic Bourke and others. Since then, the case against has had several twists and turns including dismissal of FCPA substantive charges on statute of...
View ArticleFriday Roundup
Enforcement agency speeches, “foreign official” delay, and for reading stack. It’s all here in the Friday roundup. Enforcement Agency Speeches This prior post detailed comments by Mary Jo White prior...
View ArticleRe-Scripting The Bourke Case
Frederic Bourke, “another whistleblower put in prison by the Obama administration.” So begins this recent lengthy depiction of the Bourke case on Democracy Now. Over the course of the approximate 45...
View ArticleFriday Roundup
Looking for talent – got talent, FBI announcement, Bourke related, to FCPA Inc., and for the reading stack. It’s all here in the Friday Roundup. Looking for FCPA Talent? Got Talent If your firm or...
View Article
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