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Stephen M. Byers

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Employee’s Acceptance of Gratuities Subjects Company to Heightened Liability Under Anti-Kickback Act

Posted in Legal Developments
In United States ex rel. Vavra v. Kellogg Brown & Root, Inc. (Feb. 3, 2017), the Fifth Circuit held that under Section 8706(a)(1) of the Anti-Kickback Act — permitting recovery of twice the amount of each kickback plus $11,000 for each occurrence of a prohibited conduct — corporations are liable “for the knowing violations of… Continue Reading

And Now the Carrots: DOJ Announces FCPA Self-Reporting Pilot Program

Posted in International Contracting/FCPA
On April 5, 2016, the Fraud Section of the Department of Justice’s Criminal Division launched a one-year pilot program under which companies can receive tangible credit for self-reporting violations of the Foreign Corrupt Practices Act. The rewards for self-reporting, cooperation and remediation can include avoidance of a corporate monitor, a substantial fine reduction, or declination… Continue Reading