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This Week On FCPA Professor

ThisWeekPost

FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

This guest post highlights how the Global Magnitsky Act interacts with the FCPA and other corruption prevent tools.

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FCPA Challenge

FCPA Challenge

How much do you know about the Foreign Corrupt Practices Act? Let’s find out.

To commemorate the FCPA’s 40th year, FCPA Professor is presenting the FCPA Challenge.

Each Thursday during 2018, a question will be posed and the answer will be below the fold.

This week’s question is: several large FCPA enforcement actions involved this same $6 billion liquefied national gas project.

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When A Government Customer Does Not Pay

past due

Examining the root causes of certain Foreign Corrupt Practices Act enforcement actions is not meant to rationalize or condone the conduct at issue, but just to better understand the circumstances given rise to the enforcement action in the first place.

For instance, like several other FCPA enforcement actions highlighted in this post, a root cause for a portion of the conduct alleged in the recent PDVSA related individual enforcement action is that Venezuela was unable to pay its bills and that alleged “foreign officials” offered to pay the outstanding bills (among a stack of many no doubt) in exchange for things of value.

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Associate Attorney General Rachel Brand Takes A Position At Walmart And Some People Seemingly Hyperventilate

take a deep breath

Last week, Walmart announced that DOJ Associate Attorney General Rachel Brand will “join the company as Executive Vice President, Global Governance and Corporate Secretary” and “be responsible for the organization’s Legal, Global Ethics and Compliance and Global Investigation, Security, Aviation and Travel departments, along with her role as corporate secretary.”

It was funny to see some on social media seemingly hyperventilate about this development.

Surely this must be connected to Wal-Mart’s long-standing FCPA scrutiny the inference seemed to be.

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