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Rep. Perlmutter, Once Again, Introduces FCPA Reform Bill, But This Time Goes Political


U.S. Representative Ed Perlmutter (D-CO) is persistent.

In 2009, he introduced the “Foreign Business Bribery Prohibition Act” in the House to no avail. (See here and here for prior posts). In 2011, he again introduced the “Foreign Business Bribery Prohibition Act” in the House to no avail. (See here for the prior post). In 2016, he again introduced the “Foreign Business Bribery Prohibition Act” in the House to no avail (See here for the prior post).

Last week, Perlmutter once again introduced the “Foreign Business Bribery Prohibition Act” in the House (H.R. 1549), but this time he attempted to make a political statement.

Even though H.R. 1549 is substantively the same bill as Perlmutter introduced in 2009, 2011 and 2016, the supposed purpose of H.R. 1549, as stated in his press release, is to “help stop corruption and foreign bribery under the Trump Administration.”

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Elevate Your FCPA Knowledge At The FCPA Institute – Nashville (May 4-5)

Featured Image FCPA Institute

Could someone in your firm or organization benefit from a two-day, active learning experience devoted to the Foreign Corrupt Practices Act?

If so, please consider the FCPA Institute which is next making a stop in Nashville on May 4-5.

Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of over 100 diverse professionals through active learning and the below video introduces you to the FCPA Institute; how the FCPA Institute is different than other FCPA conferences; and the substantive knowledge and practical skills participants will gain by attending the FCPA Institute.

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Scrutiny Alerts And Updates


Scrutiny alerts and updates regarding Elek Straub, Platform Speciality Products, Cobalt International, Bombardier, and the Mormon Church.

Elek Straub

In December 2011, in connection with the Foreign Corrupt Practices Act enforcement action against Magyar Telekom, the SEC also charged former Magyar Telekom executives Elek Straub (former Chairman and CEO); Andras Balogh (former Director of Central Strategic Organization); and Tamas Morvai (former Director of Business Development and Acquisitions) with various FCPA and related offenses. (See here for the prior post).

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Criminal Internal Controls Charges Against Individuals

Criminal Law

Pardon me for being that guy, but in the Foreign Corrupt Practices Act space someone needs to put on the stripes every now and then and blow the whistle on certain commentary.

Another statement (see here for a similar prior post) from Michael Volkov’s Corruption, Crime & Compliance has left me scratching my head and thinking to myself “you gotta be kidding me.” In the post, Volkov writes: “If you follow my blog, you know that I have often predicted that DOJ will eventually prosecute criminally an individual for circumventing internal controls. The implications of such a prosecution will be significant.”


As highlighted in this post, the DOJ has already criminally prosecuted several individuals for circumventing internal controls.

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Perhaps The Disclosure Approach Wasn’t Such A Bad Idea After All


This recent Wall Street Journal article titled “If You Solicit Bribes, This Fellow Wants to Punch You In the Face” caught my eye. It details a Thai man, who after years of paying bribes, became fed up with “what passes for business as usual in Bangkok” and launched a “nightly television show where he runs through the various demands for bribes and kickbacks that he says many people here endure.”

Whether this approach is reducing corruption is a debatable point, but it serves as a useful reminder that the FCPA’s current prohibition approach was not the only approach Congress considered in the mid-1970’s when considering the so-called foreign corporate payments problem.

The other approach, consistent with Louis Brandeis famous quote “sunlight is said to be the best of disinfectants,” was a disclosure approach.

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