As highlighted in this prior post, the DOJ recently announced criminal charges against Abraham Cigarroa Cervantes (a Mexican citizen described as a former finance director of the Latin America division of Stericycle).
The alleged conduct was in connection with
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Hats Off To Richard Grime
I recently saw that Richard Grime has retired. (See here).
As described in his law firm bio: “Prior to joining Gibson Dunn, Mr. Grime spent over nine years in the Division of Enforcement at the Securities and Exchange…
A Worthwhile Listen Regarding FEPA
FCPA Institute – Zoom (April 23-25)
Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of professionals from around the world. The FCPA Institute began as an in-person event, but shifted to Zoom in 2020. The Zoom event is…
DOJ Charges Another Former Stericycle Executive
Evoqua Water Technologies And Former Executive Resolve Books And Records And Internal Controls Matter
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in…
Thinking Of The FCPA And FEPA In Reverse
A public official corruptly demanded, sought, received, and accepted something of value from a company in return for being influenced in the performance of an official act – specifically agreeing to help influence the award of a contract to a…
Upcoming DOJ Whistleblower Program – How Will This Work?
A Look At The DOJ’s Justice Manual
The DOJ’s Justice Manual (JM) “provides internal DOJ guidance.” (See here).
The portion discussing the Foreign Corrupt Practices Act (Title 9-47.000) was recently updated to include the recently enacted Foreign Extortion Prevention Act (FEPA).
While the JM…
Thoughts On Recent DOJ Speeches
Reading speeches by high-ranking DOJ officials through the lens of a specific law is interesting.
For instance, in recent speeches both Deputy Attorney General Lisa Monaco and Acting Assistant Attorney General Nicole Argentieri talked about the importance of individual accountability.…