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Harvard Law Prof Is Concerned About Judicial Scrutiny Of FCPA Enforcement


Harvard Law School Professor Matthew Stephenson has an impressive background.

Yet his Foreign Corrupt Practices Act views are, well, let’s just say interesting.

Recently, in the aftermath of the Second Circuit’s decision in U.S. v. Hoskins (see here, here and here for prior posts), Stephenson further advanced his view that judicial scrutiny of FCPA enforcement is not good because the DOJ might lose.

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Summer FCPA Reading List

Summer Reading


A time for reflection, a time to think, a time to read.

If you have some downtime, put it to good use.

This post provides an overview of FCPA writings that can help you elevate your Foreign Corrupt Practices Act knowledge, sophistication, and practical skills.

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New Article: The Dun & Bradstreet Enforcement Action – A Microcosm Of The Many Problems With FCPA Enforcement


Previous posts here, here and here highlighted the recent FCPA enforcement action against The Dun & Bradstreet Corp.

Bloomberg Law White Collar Crime Report recently published my article titled “The Dun & Bradstreet Enforcement Action – A Microcosm of the Many Problems With FCPA Enforcement.

The article abstract is as follows.

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New Article – Grading The DOJ’s “FCPA Corporate Enforcement Policy”


Bloomberg BNA’s White Collar Crime Report recently published my article “Grading the DOJ’s FCPA Corporate Enforcement Policy.”

The article can be downloaded here for free and address the following issues: (i) the obvious logical gap in the Corporate Enforcement Policy (CEP); (ii) how the CEP, both in terms of rhetoric and substance, is really nothing new; (iii) ten specific reasons why the corporate community should take the CEP with a grain of salt; and (iv) how the CEP falls short of accomplishing the laudable goals articulated by the DOJ compared to other alternatives previously advanced.

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