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FCPA Flash Podcast – A Conversation With Richard Grime (Former Assistant Director of SEC Enforcement) Regarding FCPA Enforcement

FCPA Flash

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 podcast episode is a conversation with Richard Grime (Gibson, Dunn & Crutcher and former Assistant Director of SEC Enforcement) and is a must listen if you want to hear informed and candid commentary about the current FCPA enforcement landscape from someone who used to enforce the FCPA.

During the podcast, Grime discusses: (i) reasons for the general increase in FCPA enforcement (among the reasons he mentions is “the government has realized this is a money-winner”; (ii) whether FCPA enforcement, including the internal control’s provisions, has been pushed beyond the breaking point (in Grime’s words yes it has and “almost any conduct becomes subject to an enforcement vehicle”); and (iii) whether long, drawn-out FCPA investigations can be avoided.

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Former SEC FCPA Unit Chief Brockmeyer To FCPA Inc.

brockmeyer

Following in the footsteps of numerous other FCPA enforcement attorneys at the DOJ and SEC who leave government service for lucrative positions in FCPA Inc., Debevoise & Plimpton announced today that Kara Brockmeyer (who last month announced she was leaving her SEC position as FCPA Unit Chief) “is joining the firm’s Washington, D.C. office as a partner and member of the White Collar & Regulatory Defense and Strategic Crisis Response and Solutions Groups.”

See this recent post for additional data points relevant to Brockmeyer’s tenure as FCPA Unit Chief.

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Friday Roundup

Roundup

Clayton responds, from the dockets, Bitkower to FCPA Inc., and a student writing competition. It’s all here in the Friday roundup.

Clayton Responds

This previous post highlighted the FCPA portion of the recent confirmation hearing of SEC Chair nominee Jay Clayton. In follow-up written questions, Senator Sherrod Brown (D-OH) asked: “The Foreign Corrupt Practices Act (FCPA) forbids U.S. companies and their subsidiaries from paying foreign government officials to obtain or retain business. What is your specific plan for enforcement of the FCPA.”

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The Need For An FCPA Common Language – Visual Proof

visual proof

These pages have frequently highlighted the need for a Foreign Corrupt Practices Act common language as to the basic question of “what is an FCPA enforcement action?” (See here for the article “A Common Language to Remedy Distorted FCPA Enforcement Statistics” which exposes in detailed fashion distorted FCPA enforcement statistics).

As highlighted in the article, the absence of an FCPA common language has numerous negative effects including infecting nearly all FCPA enforcement statistics.

The most reliable and accurate way to keep FCPA enforcement statistics is by using the “core” approach which focuses on unique instances of FCPA scrutiny. Using this approach, there were 27 corporate FCPA enforcement actions in 2016 that resulted in approximately $2.4 billion in net FCPA settlement amounts (see here).

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Issues To Consider From The JP Morgan Enforcement Action

Issues

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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