Recently Robert Kent (Baker McKenzie) penned this article in Law360 titled “The First 6 Months of FCPA Pilot Program: 10 Lessons.”
This post contains various rebuttal points regarding the article.
First, the article implicitly asserts that the “surge” in FCPA enforcement thus far in 2016 is casually related to announcement of the April 2016 FCPA Pilot Program by the DOJ.
Yes, 2016 has been a record-breaking year for FCPA enforcement as highlighted in this post.
However, the enforcement activity is not casually related to the Pilot Program.