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Promotion of the virtual tourist card of Karlovac County on the ARZ highway

first_imgThe system of benefits for the end guest is completely free and designed in such a way that the more the guest uses it and the more savings are achieved, currently with 231 partners from the tourism and hospitality sector in the county. Definitely a recommendation for all tourism workers to join the project. Thus, for the first time, the tourist offer was united in one place via a mobile tourist card. The virtual tourist card operates on the principle of a networked offer model with incentives and discounts for tourists who decide to stay in the county. The virtual tourist card of Karlovac County called “In medias res” can be downloaded HERE As one of the first promotional activities, the arrival of guests on the ARZ motorway, more precisely at the entrance to Lučko, was wisely used from Karlovac County. In addition to guests passing through Karlovac County, this is another promotional move aimed at motivating guests to deviate from the highway on the way or return from the sea. Especially for foreign tourists, to spend at least one night, to rest from the road to the Adriatic. Presentation and promotional distribution of the Karlovac County Tourist Card on the ARZ motorway On that occasion, at the exit from the highway in Karlovac, the participants promotionally distributed the Tourist Card to tourists passing through Karlovac County. Photo: Karlovac County The director of the Karlovac County Tourist Board, Dina Begić, said that the information leaflet would be available in all tourist boards and their tourist information centers in Karlovac County, and could be purchased at tourist sites where interest was shown. Photo: Karlovac County At the beginning of July, Karlovac County presented a new tourist product – a tourist application or a virtual tourist card of Karlovac County called “In medias res”. For this occasion, 50 thousand information leaflets were printed, 35 thousand in Croatian and 15 thousand in English, which will be distributed to guests, mostly at the toll booths of the highway in Lučko and Karlovac.last_img read more

RSS Provides Lifting and Rigging Equipment to DWDR Project

first_imgRope and Sling Specialists (RSS) has supplied lifting and rigging equipment to the Dover Western Docks Revival (DWDR) project on the Kent, UK coast.RSS supplied the equipment to VolkerBrooks, part of VolkerStevin, which is one half of the VSBW joint venture with Boskalis Westminster, responsible for delivery of the marine structures and bridge contract for the landmark development.With a contract value of £115 million, the construction stage will include the design and build of two new berths, including quay walls and land reclamation; a new marina pier; the marina curve; navigation channel and new lock gates; bascule bridge and capital dredging work. VSBW recently prepared the harbor for piling and land reclamation work.Upon completion, DWDR will give Dover a transformed waterfront with a new marina pier and curve to attract a host of shops, bars, cafes and restaurants with the unique backdrop of the harbor, cliffs and castle. A new cargo terminal and distribution center will support the relocation and further development of Dover’s cargo business.The DWDR project will also create greater space within the Eastern Docks for ferry traffic and employment opportunities.last_img read more

DREAM CATCHER: Amba Etta-Tawo extended his football career while the ones around him ended

first_imgWith a wide, toothy grin, Amba Etta-Tawo walked up to cameras and recorders. The camera lights flicked on, thrusting him into the spotlight he’s constantly been in at Syracuse.He had completed the best game for an SU wide receiver in the program’s history the contest prior, racking up 270 yards and becoming the nation’s leading receiver in the process. He turned, making eye contact and giving individual reporters his attention.What’s the past week been like for you?With all this success coming, is that kind of challenging a little bit? How do you make sure you don’t get too high?AdvertisementThis is placeholder textEveryone knows you’re in the national rankings. How does it feel?He paused, likely knowing his real answer wouldn’t fit into a 30-second sound bite. He’d have to parse out his father leaving the United States, one brother’s football career cut short, another brother’s football career never starting and one of his first mentors being killed before he had graduated high school.Amba is 840 yards into his senior season — a last shot at a football dream. He’s watched so many other careers be cut short. After four disappointing seasons at Maryland, Amba transferred to Syracuse out of desperation and hope.The move propelled him to one of the most prolific seasons so far. If he keeps pace, he’ll be just the second player to cross the 2,000-receiving-yard barrier in NCAA history. He’ll likely be a contender for the Biletnikoff Award, given to college football’s best receiver. He’ll do what so many of his mentors haven’t: extend his football career.He faces the questions easily and takes them in stride. Amba gathers himself for a split second and comes up with an answer good enough for the moment, one that doesn’t involve him dissecting how he got here.“We’re just trying to focus on the next game,” he said.,Amba admitted he was slightly immature as a younger player at McEachern (Georgia) High School. His oldest brother, Etta, knew his brother didn’t take his grades as seriously as he should. One day, that spilled over to football.Amba was late to practice.Ken Hockman, Amba’s position coach, happened to be on the phone with Etta and slid the detail into their conversation.“He’ll never be late to practice again,” Hockman recalls Etta saying.Etta had been Amba’s father figure since their father, Ekure Tawo, left for Nigeria. Amba and his brother Egim say their father left in 2004. Four brothers constitute the Etta-Tawo siblings: Etta (the oldest), Egim (second oldest), Amba and Ekure (the youngest). After their father left, Etta guided the brothers alongside their mother, Stella.“When he decided to go back, I took it as my opportunity to step up and be the older figure to my younger brothers,” Etta said.The family had come from Muscat, Oman in 1999 via a Visa lottery. The brothers played soccer and lived in a 10-mile-wide private community with other expatriates, including Americans, Brits and people of other various nationalities. Every morning, the boys would take a 30 to 40 minute bus ride to a private school. There was enough space in the community for the brothers to ride bikes and roam. But before they left Muscat, an uncle told the boys they’d soon forget about soccer.“Guys, I’m telling you now,” Etta recalled the uncle telling them, “when you guys get over there, you guys are going to start playing football.”When they arrived in the United States, the family settled in Atlanta. The 1998-99 Atlanta Falcons made the Super Bowl. The brothers became fans of Jamal Anderson and the “Dirty Bird” dance he did after touchdowns.The Falcons’ success drew the oldest Etta-Tawo brother in. He won a championship in his first season playing football as a seventh grader. Amba and Egim followed their brother, each scoring touchdowns in their first recreation league games. Etta watched their careers unfold as a volunteer coach in high school. Together, the brothers were naturals. Etta eventually committed to play at Clemson.During a Monday practice in Etta’s redshirt freshman season, he felt short of breath in a helmets-only walkthrough. Etta thought the problem was a cold, but after two more days of practice, it didn’t improve. He drove with trainers to the hospital and doctors ran tests, which revealed he had an enlarged heart. Etta said he was tested for a year and a half to see whether he could return or if his condition had improved, but he never got back to the field. One of Etta’s former college teammates, Gaines Adams, collapsed and died of an enlarged heart in 2010 when he played for the Chicago Bears.“Amba and Egim sent me a long text basically saying … ‘You’re the reason I started playing football. I can’t believe this is happening, your dream is coming to an end,’” Etta said. “‘I just want you to know with everything I’ve got left in my body, I’m going to play for you, I’m going to play for Ekure, I’m going to play for mom.’“I started tearing up a little bit.”While Etta was disappointed, he realized the end of his career would help spur Egim’s and Amba’s. The latter was so small when he started playing that he hated being tackled, so much so that Hockman said the team had to manage his temper. Opponents and teammates knew it got under the young receiver’s skin. The coach estimated Amba stood 6-feet-1 but just 135 pounds in his freshman season. As a gangly player, he learned to outrun opponents to avoid tackles.Hockman had a competition for his wide receiver crew each week. Whoever had the best set of practices was allowed to wear a pair of gold Cutters gloves in McEachern’s next contest. Often, Amba and Hockman would stay late after practice and Amba would catch 80 balls from a JUGS machine. The wide receiver coach said Amba was on McEachern’s second team for a few weeks, but they quickly realized he should be moved up.Hockman saw Amba’s talent, and all he needed to do was refine and refocus it. When Amba was late to practice, his brother reminded him of what he was playing for. The talk set Amba on the right path.“When you show up to practice late, you’re telling your coaches that you don’t care about their time, that your time is better than their time and you’re better than the team,” Etta said, recalling what he told Amba. “… When you start doing stuff like that, coaches are gonna fall off, fall away from you. You may have all the talent in the world, but if you’re a knucklehead and don’t do what they tell you, then their patience is going to wear thin.”He was never late to practice again.,Amba played his first varsity football game as a sophomore at the Georgia Dome in late August of 2009. As he popped into the huddle, then-teammate Rajaan Bennett looked at him during the play call.“This is going to be a touchdown,” Amba recalls Rajaan telling him.From about 30 yards out, Amba ran a fade to the end zone. The ball floated right into his arms for his first varsity touchdown.Rajaan, McEachern’s starting running back, was a senior. Amba said the upperclassman helped calm him down on the field in what were some of his first snaps on the varsity field. The former had been friends with Egim because the two played together. When Egim left, Amba and Rajaan became lockermates. Rajaan usurped some of the role Etta and Egim had played before both left for Clemson and West Georgia, respectively. The running back had committed to Vanderbilt, was one of McEachern’s best players and was also an honor student at the high school.On the morning of Feb. 18, 2010, Amba picked up a call from McEachern quarterback Trent Thompson. He told Amba that Rajaan had been killed. Although Amba didn’t initially believe Thompson, he sobbed for a short time and went to school, hoping it was a joke. When he arrived, he found classmates crying and milling around the football field.Amba doesn’t remember many people going to class that day.According to ESPN, the following took place. Earlier that morning, the former boyfriend of Narjaketha Bennett, Rajaan’s mother, had broken into the family’s house. Narjaketha woke up with a .22-caliber pistol pointed at her. Clifton Steger, bitter over a breakup with Rajaan’s mother, had Narjaketha put her brother, who was living with the family at the time, Rajaan and her daughter in a bathroom. Rajaan’s brother was allowed to stay in a bedroom.Steger had Bennett round up the family’s cell phones. She, however, hid hers and slipped it to Rajaan while she was in the bathroom with him. Rajaan quietly called the police, who showed up. Steger sent Narjaketha out to quell the police. She left the house emotional. Steger headed with his pistol to the bathroom. Narjaketha’s brother met Steger at the bathroom first but was shot while trying to wrestle the gun away. He lived. Steger fired several shots in the bathroom.Rajaan had taken his sister into the bathtub and covered her from Steger’s shots, which pierced Rajaan’s heart and killed him. Then Steger shot himself.“When we got the news that he had passed away, I called Amba right away and he couldn’t stop sobbing,” Etta said. “Never in my life have I seen him or been around him when he’s been that upset.”After Rajaan’s death, McEachern started holding up five fingers before the opening kickoff in honor of their killed teammate because he wore No. 5. On their jerseys, the players had the No. 5 as a patch to remember Rajaan, and Etta said Amba would write a quote or two on his wrists dedicated to Rajaan. Amba was one of several players who read a poem Rajaan had written titled “Don’t Be Scared” for a class assignment before each game. It was also read at Rajaan’s funeral.“It ended up being some type of amazingly good poem,” Amba said. “We didn’t know that side of him.”Now, players all around the country wear No. 5 for Rajaan, including Oregon running back Taj Griffin, South Carolina defensive lineman Darius English and Georgia defensive lineman Julian Rochester. Amba hasn’t been able to wear No. 5. In Powder Springs, Georgia, there’s a holiday on May 21 every year named Rajaan Bennett day. Rajaan would have graduated on the date in 2010.It’s been more than six years since Rajaan’s death. Amba still plays for a fallen teammate who many said was headed for success in football or elsewhere. Talking about his friend, Amba smiles, but shortly after, his face recedes and returns to normal.“He touched a lot of people, he touched the whole community,” Amba said. “I could go on for hours and hours.”,When his older brothers left college, Amba took on the role they had played for him for Ekure. Stella wanted to keep Ekure active, so he took piano lessons. Amba decided to join in. Ekure, unlike his brothers, couldn’t play football because he has cerebral palsy, a disorder which can affect muscle movement, tone and coordination.He never played publicly, but Stella sent a video of Amba and Ekure playing together to Etta, who never thought he’d see one brother playing the piano, let alone two. Amba took the leadership void Etta and Egim vacated when they departed for college.“Amba felt like my two big brothers are gone so I gotta be big brother now and take the lead,” Etta said, “and have Ekure’s back and make sure he’s OK with everything.”The two are the nearest brothers in age (they were just a grade apart in school) and are also the closest of the brothers. Even now, Etta notices the two brothers come home for breaks and trash talk over video games, enough that Egim and Etta may tell them to cut games off and just watch television.Despite not being able to play football, the youngest Etta-Tawo would often watch his brothers’ practices. Etta said Ekure knows the most about football of the four.Egim and Amba always promised they’d play for their two brothers who had football taken from them. Not long after the older brothers left, however, Amba had to leave, too. He had committed to Randy Edsall at Maryland. In his freshman season, Amba showed promise, racking up 500 yards. The then-freshman caught his first touchdown against Clemson. Yet he’d never hit that total in a season again at UMD.After his first season, other players started above Amba on the depth chart. The Terps had future NFL players Deon Long and Stefon Diggs. When Edsall was fired, Amba knew he had a chance to find the right spot for himself. He visited Powder Springs and told Ken and Kyle Hockman he was considering Syracuse.The Hockmans came from Ohio and both had played at Bowling Green. As alumni, they knew about Dino Babers and what he could do to unlock Amba’s potential. They put in a call for Amba. Despite considering Mississippi State, Missouri and Toledo, among others, Amba cancelled all his other visits after he saw SU.Over the summer, the Syracuse wide receiver visited Los Angeles and trained with former high school teammate Chris Davis. Kavell Conner, Etta’s former roommate at Clemson and an NFL linebacker who has played for the Indianapolis Colts and San Diego Chargers, helped the two train.His family had been scheduled to take a trip to Nigeria this summer, and he would’ve visited his mother’s family. Instead, he came to Syracuse to get an early jump on adjusting. He thought it would be a bad look to go on vacation while his teammates worked toward the season.“Normally my mom would be upset with something like that,” Etta said.Amba approached his brothers before he told his mother that he’d be skipping the family trip. Etta helped reason with Stella that it was crucial for Amba to stay for his last shot at college football. She eventually grew “more than fine” with it.“That’s how I know he matured with that,” Etta said. “He decided to skip a trip around the world.”,When Etta came home on break from Clemson, he, Egim and Amba worked out together at McEachern. A group of high schoolers from a rival school showed up and challenged the brothers to a pick-up football game. Etta played quarterback and Amba was one of his wide receivers. Then a middle schooler, Amba torched the high schoolers, catching upwards of 20 passes, Etta said.For the last four years, that potential has only come in bursts. He’s finally gotten the opportunity to execute that talent while playing for the people he used to play with.On Tuesday, Amba and Eric Dungey teased each other as they were both being interviewed. Amba’s grin reappeared. And while all the football dreams of the players from the pick-up game have faded or will soon fade, his is still in progress.“I’m trying not to think too much about it,” Amba said. “I’m trying to focus on the next thing and keep on moving. At the end when everything works out, hopefully it does, I can look back at it positively.”As Amba stopped joking with Dungey, he pivoted and walked through double doors out of the foyer of the Petty-Iacolano Football Wing with the grin still on his face.,Banner photo by Bryan Cereijo | Staff Photographer Published on October 6, 2016 at 12:39 am Contact Chris: cjlibona@syr.edu | @ChrisLibonati,Cancel replyYou must be logged in to post a comment. Commentslast_img read more

The Supreme Courts Recent Unanimous Decision In A Restitution Case Provides Yet

first_img Learn More & Register The scenario is relatively common. Whether in the Foreign Corrupt Practices Act context or otherwise, an individual acts contrary to the law and when his or her conduct is discovered various business organizations impacted by the illegal activity conduct an internal investigation.The question arises: if the individual engaged in the illegal activity is convicted, may the impacted business organizations recover from the individual internal investigation expenses under the Mandatory Victims Restitution Act (MVRA) and, if so, under what circumstances? In recent years, circuit courts have split on the relevant issues.Last week though the Supreme Court provided clarity in Lagos v. U.S. In the unanimous decision authored by Justice Breyer, the court concluded that the words “investigation” and “proceedings” in the MVRA are limited to government investigations and criminal proceedings. After excerpting the case, this post highlights how business organizations can best position themselves for MVRA restitution in certain FCPA matters by not voluntarily disclosing.As to the relevant factual background, the opinion states:“The petitioner, Sergio Fernando Lagos, was convicted of using a company that he controlled (Dry Van Logistics) to defraud a lender (General Electric Capital Corporation, or GE) of tens of millions of dollars. The fraud involved generating false invoices for services that Dry Van Logistics had not actually performed and then borrowing money from GE using the false invoices as collateral. Eventually, the scheme came to light. Dry Van Logistics went bankrupt. GE investigated. The Government indicted Lagos. Lagos pleaded guilty to wire fraud. And the judge, among other things, ordered him to pay GE restitution. The issue here concerns the part of the restitution order that requires Lagos to reimburse GE for expenses GE incurred during its own investigation of the fraud and during its participation in Dry Van Logistics’ bankruptcy proceedings. The amounts are substantial (about $5 million), and primarily consist of professional fees for attorneys, accountants, and consultants. The Government argued that the District Court must order restitution of these amounts under the Mandatory Victims Restitution Act because these sums were “necessary . . . other expenses incurred during participation in the investigation . . . of the offense or attendance at proceedings related to the offense.” The District Court agreed, as did the U. S. Court of Appeals for the Fifth Circuit. Lagos filed a petition for certiorari. And in light of a division of opinion on the matter, we granted the petition.”As to the relevant legal background and issue presented, the opinion states:“The [MVRA] of 1996 requires defendants convicted of a listed range of offenses to “reimburse the victim for lost income and necessary child care, transportation, and other expenses incurred during participation in the investigation or prosecution of the offense or attendance at proceedings related to the offense.”[…]The [MVRA] is one of several federal statutes that govern federal court orders requiring defendants convicted of certain crimes to pay their victims restitution. It concerns “crime[s] of violence,” “offense[s] against property . . . , including any offense committed by fraud or deceit,” and two specific offenses, one concerning tampering with a consumer product and the other concerning theft of medical products. It requires, in the case of property offenses, return of the property taken or its value; in the case of bodily injury, the payment of medical expenses and lost income; in the case of death, the payment of funeral expenses; and, as we have said …. in all cases, “reimburse[ment]” to “the victim for lost income and necessary child care, transportation, and other expenses incurred during participation in the investigation or prosecution of the offense or attendance at proceedings related to the offense.” (emphasis added).”The opinion then states:“We here consider the meaning of that italicized phrase. Specifically, we ask whether the scope of the words “investigation” and “proceedings” is limited to government investigations and criminal proceedings, or whether it includes private investigations and civil or bankruptcy litigation. We conclude that those words are limited to government investigations and criminal proceedings.Our conclusion rests in large part upon the statute’s wording, both its individual words and the text taken as a whole. The individual words suggest (though they do not demand) our limited interpretation. The word “investigation” is directly linked by the word “or” to the word “prosecution,” with which it shares the article “the.” This suggests that the “investigation[s]” and “prosecution[s]” that the statute refers to are of the same general type. And the word “prosecution” must refer to a government’s criminal prosecution, which suggests that the word “investigation” may refer to a government’s criminal investigation. A similar line of reasoning suggests that the immediately following reference to “proceedings” also refers to criminal proceedings in particular, rather than to “proceedings” of any sort.Furthermore, there would be an awkwardness about the statute’s use of the word “participation” to refer to a victim’s role in its own private investigation, and the word “attendance” to refer to a victim’s role as a party in noncriminal court proceedings. A victim opting to pursue a private investigation of an offense would be more naturally said to “provide for” or “conduct” the private investigation (in which he may, or may not, actively “participate”). And a victim who pursues civil or bankruptcy litigation does not merely “atten[d]” such other “proceedings related to the offense” but instead “participates” in them as a party. In contrast, there is no awkwardness, indeed it seems perfectly natural, to say that a victim “participat[es] in the investigation” or “attend[s] . . . proceedings related to the offense” if the investigation at issue is a government’s criminal investigation, and if the proceedings at issue are criminal proceedings conducted by a government.Moreover, to consider the statutory phrase as a whole strengthens these linguistic points considerably. The phrase lists three specific items that must be reimbursed, namely, lost income, child care, and transportation; and it then adds the words, “and other expenses.” Lost income, child care expenses, and transportation expenses are precisely the kind of expenses that a victim would be likely to incur when he or she (or, for a corporate victim like GE, its employees) misses work and travels to talk to government investigators, to participate in a government criminal investigation, or to testify before a grand jury or attend a criminal trial. At the same time, the statute says nothing about the kinds of expenses a victim would often incur when private investigations, or, say, bankruptcy proceedings are at issue, namely, the costs of hiring private investigators, attorneys, or accountants. Thus, if we look to noscitur a sociis, the well-worn Latin phrase that tells us that statutory words are often known by the company they keep, we find here both the presence of company that suggests limitation and the absence of company that suggests breadth.We add a practical fact: A broad reading would create significant administrative burdens. The statute provides for mandatory restitution, and the portion we construe is limited to “necessary . . . other expenses.” The word “necessary” would, if the statute is broadly interpreted, invite disputes as to whether particular expenses “incurred during” participation in a private investigation or attendance at, say, a bankruptcy proceeding, were in fact “necessary.” Such disputes may become burdensome in cases involving multimillion dollar investigation expenses for teams of lawyers and accountants. A district court might, for example, need to decide whether each witness interview and each set of documents reviewed was really “necessary” to the investigation. Similarly, the statute also limits restitution to expenses incurred only during “attendance at proceedings related to the offense,” inviting disputes as to whether, say, a licensing proceeding, a human resources review, an in-house disciplinary proceeding, a job interview, a Consumer Product Safety Commission hearing, or a neighborhood watch meeting qualified as “proceedings” sufficiently “related to the offense” so as to be eligible for restitution.To interpret the statute broadly is to invite controversy on those and other matters; our narrower construction avoids it. And one begins to doubt whether Congress intended, in making this restitution mandatory, to require courts to resolve these potentially time-consuming controversies as part of criminal sentencing—particularly once one realizes that few victims are likely to benefit because more than 90% of criminal restitution is never collected.There are, of course, contrary arguments—arguments favoring a broad interpretation. The Government points out, in particular, that our narrow interpretation will sometimes leave a victim without a restitution remedy sufficient to cover some expenses (say, those related to his private investigation) which he undoubtedly incurred as a result of the offense. Leaving the victim without that restitution remedy, the Government adds, runs contrary to the broad purpose of the [MVRA], namely, “to ensure that victims of a crime receive full restitution.”But a broad general purpose of this kind does not always require us to interpret a restitution statute in a way that favors an award. After all, Congress has enacted many different restitution statutes with differing language, governing different circumstances. Some of those statutes specifically require restitution for the “full amount of the victim’s losses,” defined to include “any . . . losses suffered by the victim as a proximate result of the offense.” The [MVRA], however, contains no such language; it specifically lists the kinds of losses and expenses that it covers. Moreover, in at least one other statute Congress has expressly provided for restitution of “the value of the time reasonably spent by the victim in an attempt to remediate the intended or actual harm incurred by the victim from the offense. Again the [MVRA] has no similar provision. And given those differences between the [MVRA] and other restitution statutes, we conclude that the considerations we have mentioned, particularly those based on a reading of the statute as a whole, tip the balance in favor of our more limited interpretation.We add that this interpretation does not leave a victim such as GE totally without a remedy for additional losses not covered by the [MVRA] GE also brought a civil lawsuit against Lagos for the full extent of its losses, and obtained an over-$30 million judgment against him. The Government says that GE has largely been unable to collect on that judgment, but there is no reason to think that collection efforts related to a criminal restitution award would prove any more successful.The Government makes one additional argument. It points out that GE shared with the Government the information that its private investigation uncovered. And that fact, the Government says, should bring the expenses of that investigation within the terms of the statute even if the “investigation” referred to by the statute is a government’s criminal investigation. The short, conclusive answer to that claim, however, lies in the fact that the statute refers to “necessary child care, transportation, and other expenses incurred during participation in the investigation or prosecution of the offense.”  It does not refer to expenses incurred before the victim’s participation in a government’s investigation began. And the Government does not deny that it is those preparticipation expenses—the expenses of conducting GE’s investigation, not those of sharing the results from it—that are at issue here. We therefore need not address in this case whether this part of the [MVRA] would cover similar expenses incurred during a private investigation that was pursued at a government’s invitation or request. It is enough to hold that it does not cover the costs of a private investigation that the victim chooses on its own to conduct. (emphasis added).For the reasons stated, we conclude that the words “investigation” and “proceedings” in the [MVRA] refer to government investigations and criminal proceedings. Consequently Lagos is not obliged to pay the portion of the restitution award that he here challenges. We reverse the Court of Appeals’ judgment to the contrary, and we remand the case for further proceedings consistent with this opinion.”From an FCPA perspective, the key language in the court’s unanimous opinion is highlighted above in bold. In other words, it will be difficult for a business organization to seek restitution for investigative fees and expenses if those fees and expenses were the result of a voluntary disclosure (in other words, not a pro-active government investigation).On the other hand, if a business organization incurs investigate fees and expenses after being contacted by the government, a business organization is better positioned for MVRA restitution.As highlighted in numerous prior posts (see here and here for recent examples), there are many reasons why business organizations should pause before voluntarily disclosing alleged FCPA violations. The Supreme Court’s unanimous decision in Lagos is yet another reason to pause. FCPA Institute – Boston (Oct. 3-4) A unique two-day learning experience ideal for a diverse group of professionals seeking to elevate their FCPA knowledge and practical skills through active learning. Learn more, spend less. CLE credit is available.last_img read more