

The FCPA Files: R. Eugene Holley and Roy J. Carver (Holcar Oil Company) (1979)
It must have seemed like a great opportunity: three offshore wells in Qatar, pre-drilled, just waiting for someone to reopen them and...

BriberyMatters
Nov 19, 20242 min read


The DOJ’s Telefónica Enforcement: Looking for Roaming Charges?
Last week, the U.S. Department of Justice announced that a subsidiary of Spanish company Telefónica S.A. agreed to pay $85.2 million ...

Dave Lee
Nov 15, 20243 min read


The FCPA Files: Page Airways, Inc. (1978)
From its debut in 1966, the Grumman Gulfstream II jet stood out as a turbo-powered symbol of luxury business travel. With room for a dozen..

BriberyMatters
Nov 14, 20242 min read


The FCPA Files: Kenny International (1979)
Finbar Kenny was a philatelist and entrepreneur: postage stamps were his game. After decades as the manager of Macy’s stamp department...

BriberyMatters
Nov 12, 20242 min read


The FCPA Files: What Can We Learn From Old Cases?
The FCPA will turn fifty in a few years, giving rise to the inevitable host of celebrations and retrospectives. But we don’t need to wait...

BriberyMatters
Nov 7, 20242 min read


To Build a Circle of Trust, Explain to Employees Why Conflicts of Interest Matter
It is a good strategy to remind your internal client groups from time to time where to find company policies and why they exist in the...

Lee Nelson
Oct 31, 20243 min read
