44 ARTICLE NO SAFE HAVEN: DOJ CAN AND WILL SEIZE PROCEEDS OF WHOLLY FOREIGN CORRUPTION By Kathleen Hamann & David R. Courchaine (USA) Authors Kathleen Hamann Carleton College (1993) Georgetown University Law Center (2003) Adjunct Professor of international law, American University Washington College of Law, Washington, D.C. and Partner, White & Case LLP 1 E-mail: kathleen.hamann@whitecase.com David R. Courchaine University of Chicago (2007) American University Washington College of Law (2010) Associate, White & Case LLP’s Global White Collar Practice Group2 1 Kathleen Hamann focuses her practiceon international and transnational government investigations and compliance matters, with substantial experience regarding enforcement of the Foreign Corrupt Practices Act (FCPA) and multijurisdictional government investigations. <...> Ms. Hamann joined White & Case after almost two decades of federal service at the U.S. Department of Justice (DOJ) and in the U.S. diplomatic corps. <...> While in the diplomatic corps, she was one of the negotiators of the ‘no safe haven’ initiative and worked extensively on kleptocracy issues. <...> She was the longest-tenured prosecutor in the FCPA Unit at the DOJ at the time of her departure and also acted as international policy counsel to the Fraud Section, advising on matters such as data privacy, sovereign immunity, and international conflict of laws. 2 David R. Courchaine focuses his practice on white collar criminal defense, government investigations, corporate internal investigations, and corporate compliance matters. <...> He represents foreign and domestic clients in fraud and anti-corruption matters involving the DOJ, the U.S. Securities and Exchange Commission, the U.S. Commodity Futures Trading Commission, and other federal and state entities in multiple jurisdictions. <...> He has experience representing multinational corporations in matters involving the FCPA, including management of complex internal investigations, as well as matters involving the federal antitrust laws. www.kulawr.ru Volume 2 May 2015 Issue 1(3) KUTAFIN UNIVERSITY LAW REVIEW Kathleen Hamann & David R. Courchaine No Safe Haven: DOJ Can and Will Seize Proceeds of Wholly Foreign Corruption Abstract A recent civil forfeiture complaint filed by the U.S. Department of Justice <...>