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FCPA Unit Chief Kahn On Multijurisdictional Cases


Recently, DOJ Foreign Corrupt Practices Act Unit Chief Daniel Kahn penned an article in the Department of Justice Journal of Federal Law and Practice titled “Responding to the Upward Trend of Multijurisdictional Cases: Problems and Solutions.”

The Journal of Federal Law and Practice is the renamed United States Attorneys’ Bulletin and compared to delivering speeches, it is nice to see our public officials write articles (complete with certain footnotes) on topics they oversee.

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It’s A Foreign Corrupt Practices Act World


The Foreign Corrupt Practices Act was once viewed as “little more than a policy assertion” and a “very difficult if not impossible” law to enforce.

However, the FCPA has ensnarled a wide range of companies that offer products and services that impact and/or improve our daily lives.

In recognition of the FCPA’s 40th anniversary, the over 200 companies that have resolved FCPA enforcement actions are weaved into a fictional story to demonstrate that it truly is a Foreign Corrupt Practices Act world!

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Scrutiny Alerts

CHS Inc., an agricultural cooperative, disclosed:

“In the fourth quarter of fiscal 2018, we contacted the U.S. Department of Justice and SEC to voluntarily self-disclose potential violations of the FCPA in connection with a small number of reimbursements the Company made to Mexican customs agents in the 2014-2015 time period for payments the customs agents made to Mexican customs officials in connection with inspections of grain crossing the U.S.-Mexican border by railcar. We are fully cooperating with the government, including with the assistance of legal counsel, which assistance includes investigating other areas of potential interest to the government. We are unable at this time to predict when our or the government agencies’ review of these matters will be completed or what regulatory or other outcomes may result.”

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This Week On FCPA Professor


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.

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Trump, The $50 Million Dollar Moscow Penthouse, And The FCPA


There are some people convinced that businessman Donald Trump must have violated the Foreign Corrupt Practices Act given his international real estate projects and other business ventures. In the past few years, I spoken to several journalists, both before November 2016 and after, about such issues but I have never been quoted in any of the articles because my legal analysis of the information provided did not fit the narrative the journalist was pursuing. (See here and here for example).

The latest FCPA article regarding Trump is here from Bloomberg and states:

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