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Issues To Consider From The JP Morgan Enforcement Action


This previous post went in-depth into the recent Foreign Corrupt Practices Act enforcement action against JP Morgan based on its alleged improper hiring and internship practices that the U.S. government labeled bribery and corruption

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

Other Internship / Hiring Enforcement Actions

While the JPMorgan hiring and internship enforcement action was the most high-profile based on the settlement amount, it certainly was not the first FCPA enforcement action based on alleged improper internship and hiring practices.

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Friday Roundup


Checking in on Wal-Mart, DOJ “declinations,” another installment of as we say not as we do, scrutiny alerts, and cashing in. It’s all here in the Friday roundup.


In its recent 2Q FY2017 earnings call presentation Wal-Mart disclosed $28 million in Foreign Corrupt Practices Act and compliance related expenses ($23 million for ongoing investigations and inquiries and $5 million for global compliance program and organizational enhancements). The Q2 expenses of $28 million are higher than the Q1 expenses of $25 million.

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Friday Roundup


Scrutiny alerts and updates, sentenced, asset recovery, to FCPA Inc., across the pond, quotable and for the reading stack.

It’s all here in the Friday roundup.

Scrutiny Alerts and Updates

Grupo Televisa

This Wall Street Journal article concerns Grupo Televisa SAB, a Mexican broadcaster with shares traded on the NYSE. According to the article:

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A Q&A Regarding “A Common Language to Remedy Distorted FCPA Enforcement Statistics”


My article “A Common Language to Remedy Distorted FCPA Enforcement Statistics” (click here to download) was recently published in the Rutgers Law Review.

The article discusses how various FCPA Inc. participants have adopted creative and haphazard counting methods that infect the quality and reliability of FCPA enforcement and related statistics of interest to many in the legal and business communities. The article also highlights how the lack of an FCPA common language has several negative effects including the quality of FCPA lawyering, the quality of empirical FCPA research, and the quality of FCPA reporting by the media.

The article concludes by proposing a FCPA common language that can improve the quality and reliability of FCPA statistics and thus allow a more cogent conversation to take place regarding FCPA issues.

I elaborate on various issues discussed in the article in a Q&A recently published in Bloomberg BNA’s White Collar Crime Report – “How a Common Language for the FCPA Would Help all Participants” (May 13, 2016).

The Q&A is set forth below.

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