Jessica Piquet Megaw

Jessica Piquet Megaw

Jessica Piquet Megaw is an associate based in Steptoe’s Washington office.  She focuses on compliance and investigations involving the Foreign Corrupt Practices Act (FCPA).

View Ms. Megaw’s full bio.

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The DOJ’s New FCPA Corporate Enforcement Policy: Dangling Presumptive Declination as an Incentive for Voluntary Disclosure

As we discussed in last week’s blog post, on November 29, 2017, Deputy Attorney General Rod J. Rosenstein made remarks at the American Conference Institute’s 34th International Conference on the Foreign Corrupt Practices Act (FCPA) recognizing the success of the FCPA Enforcement Plan and Guidance (commonly referred to as the FCPA “Pilot Program”), which had … Continue Reading

Deputy Attorney General Rosenstein Announces Significant New FCPA Corporate Enforcement Policy

Yesterday, in remarks made at the 34th International Conference on the FCPA, Deputy Attorney General Rod J. Rosenstein recognized the success of the FCPA Pilot Program and announced a revised FCPA Corporate Enforcement Policy geared at “increas[ing] the volume of voluntary disclosures” and “enhanc[ing] the [DOJ’s] ability to identify and punish culpable individuals.”  A transcript … Continue Reading

In the Wake of Kokesh v. SEC: Whither Disgorgement in FCPA Cases

On June 5, 2017, the United States Supreme Court unanimously held that disgorgement in SEC enforcement actions operates as a penalty in Kokesh v. Securities and Exchange Commission.  This means that disgorgement is subject to the federal five-year statute of limitations under 28 U.S.C. §2462. The Kokesh decision settled a dispute between the US Court … Continue Reading

World Bank’s Integrity Vice Presidency Releases Annual Integrity Update

On October 7, the World Bank Group (the Bank) Integrity Vice Presidency (INT) released its Annual Update for the 2016 Fiscal Year (the FY2016 Report or the Report).  This Report emphasizes INT’s endeavor to protect Bank-funded procurement projects in the immediately preceding fiscal year, and sets out INT’s current and future policy, investigation, and enforcement … Continue Reading

OFAC Penalizes Barclays for Zimbabwe Sanctions Violations

On February 8, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $2,485,890 settlement with Barclays Bank Plc (“Barclays”).  According to the settlement announcement, Barclays processed 159 U.S.-dollar (“USD”)-denominated transactions on behalf of Barclays Bank of Zimbabwe Limited (“Barclays Zimbabwe”) between July 2008 and September 2013.  OFAC stated that … Continue Reading
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