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1960s MAN THINKING HAND PENCIL ON CHIN WEARING EYEGLASSES SERIOUS EXPRESSION

This recent Wall Street Journal Risk & Compliance Journal post by an individual new to the Foreign Corrupt Practices Act space reads in full:

“A U.S. Justice Department program that incentivizes companies to self-report foreign corruption is making headway as prosecutors look for ways to hold individuals accountable for wrongdoing, according to an official in the department’s Foreign Corrupt Practices Act unit.”

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The Many Issues To Consider From The Cognizant Technology Enforcement Action

Issues

Previous posts here and here highlighted the recent Foreign Corrupt Practices Act enforcement action against Cognizant Technology Solutions and two of its former executives.

This post continues the analysis by highlighting several issues to consider.

Timeline

As highlighted in this prior post, Cognizant disclosed its FCPA scrutiny in a September 2016 SEC filing. Thus from start to finish, Cognizant’s FCPA scrutiny lasted approximately 2.5 years. While 2.5 years is shorter than recent medians of over 4 years (see here), 2.5 years is still too long for FCPA scrutiny to last.

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FCPA Flash Podcast – A Conversation With Kevin Abikoff Regarding FCPA Compliance Challenges And Other Developments

Podcast Logo

The FCPA Flash podcast provides in an audio format the same fresh, candid, and informed commentary about the Foreign Corrupt Practices Act and related topics as readers have come to expect from written posts on FCPA Professor.

This FCPA Flash episode is a conversation with Kevin Abikoff (Co-chair of Hughes Hubbard & Reed’s Anti-Corruption and Internal Investigations Practice Group). In the podcast, Abikoff discusses: FCPA compliance challenges; his top two legal or policy developments in 2018 in the FCPA space; and whether the FCPA has truly been successful in achieving its objectives.

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DOJ’s Cronan On The “Importance Of Law Enforcement And Private Industry Working Together” (With Rebuttal Points)

workingtogether

Yesterday, DOJ Principal Deputy Assistant Attorney General John Cronan delivered this speech “about the importance of law enforcement and private industry working together in pursuit of common, shared objectives.”

Cronan’s speech touched upon a number of topics including the DOJ’s FCPA Corporate Enforcement Policy, so-called declinations, transparency in law enforcement, and merger and acquisition issues. This post excerpts the speech and provides various rebuttal points.

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