Aisling O’Shea Quoted in The Anti-Corruption Report Article

May 2, 2018
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Aisling O'Shea was quoted in The Anti-Corruption Report's article “Dun & Bradstreet Settles for $9 Million with SEC and Receives DOJ Declination for China Subsidiary Misconduct” on May 2. In discussing the retroactive application of the FCPA Corporate Enforcement Policy, Aisling said, “The public nature of the declination makes clear that this was otherwise a case 'that would have been prosecuted or criminally resolved' but for the policy-related considerations set forth in the declination letter.” In discussing the current administration's emphasis on consistency in decision-making, Aisling said, “While the policy is not technically binding on cases that began prior to its taking effect, shortly after the policy was announced, Daniel Kahn, the Chief of the DOJ FCPA Unit, stated his intention to treat all companies and cases consistently under the policy.”