Facilitating Payments or Bribes?

As Mike Koehler explains in his latest piece, where a facilitating payment ends and where a payment to "obtain or retain business" begins is a difficult question.

Two-Tiered FCPA Justice?

As Mike Koehler points out in his latest column, the seemingly uneven treatment of big companies like Daimler, BAE, and Siemens as compared to individuals like Charles Paul Edward Jument raises the question of whether there is a two-tiered system for FCPA justice.

Jurors in William Jefferson Case Speak

In August 2009, former Congressman William Jefferson was found guilty by a federal jury of a variety of charges, but not guilty of a substantive FCPA charge. We now have some insight into why this was the case.

HP Execs Embroiled in Bribery Investigation

  • April 15, 2010

Several execs and employees of HP are being investigated by German and Russian authorities for paying bribes to foreign officials to win a lucrative contract. The investigation brings up a bevy of potential FCPA issues as well.

Clarifying Comments

From time to time, one's ideas and opinions can be taken a bit out of context and that is, Mike Koehler believes, what occurred in a recent Corporate Crime Reporter article.

Disgorgement: The Devil You Don’t Know

Sasha Kalb and Marc Bohn of Miller & Chevalier provide an in-depth examination of the SEC's application of disgorgement - the remedy used to deprive wrong-doers of their ill-gotten gains and deter violations of federal securities law - in FCPA resolutions.

End of Grease Payments Coming

As explained by FCPA Compliance attorney Thomas Fox, an announcement by the OECD a few months ago should bring the considerable problems associated with facilitation in the international business arena into keener focus.