Editor's note.

• Jurisdiction: United States
• Author: Glandon, Kevin R.
• Date: 22 March 2010

Welcome to the Twenty-Fifth Edition of the Annual Survey of White Collar Crime. Our goal every year is to provide readers with current and relevant information regarding federal white collar criminal offenses. To that end, this issue includes an introductory essay and a policy proposal. The essay examines the trend toward increasing enforcement of and penalties for Foreign Corrupt Practices Act ("FCPA") violations and the need for the adoption of an FCPA leniency policy to correct an incentive structure that currently discourages corporate internal investigations and self-reporting. The policy proposal urges that federal officials cease ignoring kickback arrangements in the healthcare sector aimed at private pay patients, which are impacting the integrity and cost of the nation's healthcare systems and can and should be prosecuted as federal crimes.

Robert W. Tarun and Peter P. Tomczak have authored the introductory essay, entitled A Proposal for a United States Department of Justice Foreign Corrupt Practices Act Leniency Policy. As prosecutions for FCPA violations dramatically increase along with sanctions and penalties, the essay sounds a...