The Strategy That Helped a Former Embraer Sales Manager Avoid Jail Time

How did Colin Steven, a former Embraer regional sales manager who pled guilty to FCPA charges for his role in Embraer’s bribery scheme escape a prison sentence? Rather than require jail time or probation, SDNY Judge Alison Nathan ordered Steven to forfeit the proceeds he received as part of the deal and pay a $25,000 fine. The Anti-Corruption Report recently spoke with Steven’s defense team at Arnold & Porter about his cooperation with the government and how they convinced the prosecutors and judge that jail time was not appropriate in this matter. See “An Enforcement Trend? The DOJ Pursues Individuals in Diverse Industries” (Feb. 21, 2018).

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