Jacqueline C. Wolff
Something Old, Something New, Something Borrowed, Something Blue
this second edition contains some new “hypotheticals” — facts of actual cases the DOJ finds important enough to focus on — and, in keeping true to its name, has included additional resources and links for chief compliance officers looking to design and audit their companies’ anticorruption compliance programs.
Robert J. Anello and Richard F. Albert
United States v. Napout
The U.S. government’s lead role in the prosecution of corruption within the Zurich-based FIFA may be a paradigmatic example of U.S. law enforcement acting as the world’s policeman. If corruption is based on foreign executives violating their duties of loyalty to foreign private entities, how does that translate into a violation of U.S. criminal law? Does it matter that the conduct in which the foreign executive engaged — commercial bribery — may not be illegal under the law of the executive’s home country?
Elkan Abramowitz and Jonathan S. Sack
This article discusses cases that have begun to address whether “official act” is an element in a private honest services fraud prosecution.