Gary Kalman on Corruption and Compliance Programs
In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more
In March, the Department of Justice (DOJ) announced that a pilot program to incentivize individualized reporting was in development, which we reviewed here. True to its word, the DOJ's "Corporate Whistleblower Awards Pilot...more
On June 26, 2024, the U.S. Supreme Court issued an opinion in a public corruption case that could have a lasting impact on how the U.S. Government prosecutes corruption and procurement fraud cases involving state and local...more
On June 26, 2024, the U.S. Supreme Court found that the main federal anti-corruption statute proscribing bribes to state and local officials does not criminalize gratuities, which the Court described as “payments made to an...more
The US Supreme Court’s June 26 ruling in Snyder v. United States clarified that the primary federal law regulating state and local corruption, 18 USC § 666, does not bar state and local officials from accepting...more
Last month, in Snyder v. United States, the Supreme Court of the United States narrowly construed the federal anti-bribery statute. In that case, the mayor of Portage, Indiana worked with other officials to carefully prepare...more
Who would have thought politicians can work for tips? Well, that is what Portage, Indiana Mayor Jim Snyder argued (more or less) before the Supreme Court last month, when he sought to overturn his conviction under 18 U.S.C. §...more
The Supreme Court yet again unanimously overturned bribery convictions based on prosecutorial overreach via the honest services wire fraud statute. The steady stream of reversals fundamentally challenges the DOJ’s approach in...more
Can a private citizen who holds no elected office or government position owe a fiduciary duty to the general public such that he can be convicted of honest services fraud? On June 30, 2022, the Supreme Court granted...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) is urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption; the Financial Industry Regulatory Authority...more
The playing field for anticorruption never stops changing, with new laws and new risks constantly arising. To help sort things out, and to gain his insight into other compliance challenges, we sat down with Gary Kalman,...more
On Tuesday, former New York State Assembly Speaker Sheldon Silver received a welcomed victory, albeit partial, in the Government’s long running prosecution accusing him of fraud, extortion and money laundering....more
Last week, the U.S. Attorney’s Office for the Eastern District of Virginia moved to dismiss public corruption charges against former Virginia Governor Robert McDonnell, and his wife, Maureen McDonnell. The decision comes...more