No Sex Please, We’re the SEC
Earlier this month, Deere & Company agreed with the SEC to disgorge about $4.3 million in profits and pay roughly $5.4 million in fines ...
Dave Lee
Sep 24, 20242 min read
Are the Menendez and Cuellar FARA Charges Unconstitutional?
One of the most significant anti-corruption developments of 2024 has been the use of a previously little used statute, 18 USC 219, to...
Tom Firestone
Sep 17, 20244 min read
U.S. DOJ Declines to Prosecute Boston Consulting Group After It Admits to Paying Bribes in Angola – Practitioner Takeaways
Last week, Boston Consulting Group (BGC) announced that the U.S. Department of Justice (DOJ) declined to prosecute the firm despite...
Dave Lee
Sep 5, 20242 min read
Has the DOJ Silenced its Most Important Whistleblowers? Foreign Corruption and DOJ’s New Whistleblower Program
1. Introduction On August 1, 2024, the U.S. Department of Justice (DOJ) launched the Corporate Whistleblower Awards Pilot Program...
Billy Jacobson
Aug 29, 20248 min read
Debunking “Too Big to Debar” (Again)
Sometimes I feel like combatting debarment misinformation is a part-time job. Anytime misconduct involving a government...
Jessica Tillipman
Aug 20, 20244 min read
Whistleblower rewards work. So why isn’t the world embracing them?
Corruption is notoriously difficult to detect. As I describe in the book that I recently published...
Jessica Tillipman
Jun 13, 20244 min read