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Assistant Attorney General Benczkowski On … With Rebuttal Points

benczkowski

Another day another Foreign Corrupt Practices Act speech by a Department of Justice official.

Earlier today Assistant Attorney General Brian Benczkowski talked about mutual interests between the DOJ and business organizations, transparency, and the DOJ FCPA corporate enforcement program.

This post excerpts the speech and provides various rebuttal points.

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Deputy Attorney General Rosenstein Delivers Yet Another FCPA Speech … With Rebuttal Points

rosenstein

Yet another Foreign Corrupt Practices Act speech by Deputy Attorney General Rod Rosenstein.

(See here, here, here, here and here for other recent speeches).

This post excerpts the speech and provides various rebuttal points using actual facts.

Rosenstein began his speech talking about general issues and stated:

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Deputy AG Rosenstein On ….

rosenstein

Recently outgoing Deputy Attorney General Rod Rosenstein delivered this speech to a university audience. Like many of Rosenstein’s prior speeches highlighted on these pages, the speech was a pleasure to read for its general advice.

For instance, Rosenstein stated: “Today, you are relentlessly bombarded with information, much of it of unknown reliability. The internet lets people share their most ignorant thoughts. Many news stories rely on anonymous sources, without providing details to assess their credibility and bias. Some critics worry that our society will be unable to distinguish fact from opinion, and truth from fiction.”

Perhaps Rosenstein was talking about certain FCPA commentary? (See here, here and here for instance).

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SEC Co-Director Of Enforcement Peikin On International Cooperation

Peikin

Recently Steven Peikin (Co-Director of the SEC’s Enforcement Division) delivered this speech in which he talked about international cooperation and how it is “critical to the SEC’s civil law enforcement success” including the Foreign Corrupt Practices Act space.

In addition, Peikin stated that “vigorous enforcement of the FCPA remains a high priority for the SEC.”

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Lisa Osofsky (Director Of U.K. Serious Fraud Office) Speaks On A Variety Of Topics

osofsky

U.S. enforcement officials are not the only ones who speak at FCPA conferences hosted by for-profit conference firms. (See here). “Foreign officials” do as well.

So let’s see, the conference firms are “domestic concerns” under the FCPA, a speaking slot is a thing of value, the foreign law enforcement official is a “foreign official,” and the thing of value to the foreign official helps drive attendance to the conference firm’s paid event. But, I digress.

Recently, Lisa Osofsky (Director of the U.K. Serious Fraud Office) delivered this speech at an FCPA conference and touched upon the following topics: SFO priorities, international cooperation, corporate cooperation and integrity, and the SFO’s use of technology.

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