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Andrew Weissmann On The FCPA – It Is “Very Easy For The People At The DOJ And SEC To Basically Impose A Tax For Doing Business” In Certain Countries


One of more concerning aspects of the Foreign Corrupt Practices Act landscape is the extent to which current FCPA enforcement officials have articulated seemingly contradictory positions prior to or after their stint at the DOJ or SEC. For instance, see prior posts here (“A Former Enforcement Official Is Likely to Say (Or Has Already Said) the Same Thing”) and here (“In the FCPA Space, Who Speaks for Whom?”).

FCPA Professor was the first to highlight the seeming irony when vocal FCPA enforcement critic and reform advocate Andrew Weissmann was selected to head the DOJ’s fraud section in January 2015 and how Weissmann should have stayed true to his former self when unveiling the DOJ’s “FCPA Pilot Program” in April 2016.

Weissmann’s prior positions on the FCPA are nicely captured in a 2010 panel event in which he speaks at great length regarding various aspects of the FCPA.

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Friday Roundup


From the dockets, you gotta be kidding me, it’s a numbers game, former DOJ FCPA Unit Chief Duross on …, scrutiny updates, a foreign official teaser, a bracket of a different kind, and an event notice. It’s all here in the Friday Roundup.

From The Dockets

Two developments in DOJ FCPA individual actions.

One the DOJ apparently wants you to do know about because it issued a press release, the other apparently not because there was no press release.

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Friday Roundup


Not something you see everyday, Yates Memo related, quotable, scrutiny alerts and updates, and for the reading stack. It’s all here in the Friday roundup.

Not Something You See Everyday

It’s not everyday that you see a director of a publicly-traded company publicly resign because the director thinks the company is engaged in improper conduct including FCPA violations.

But that is just what Michael Moss, until recently a director of Malvern Bancorp, did.

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FCPA Flash – A Conversation With Paul Pelletier

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The new FCPA Professor contains a new feature – the FCPA Flash podcast.

The goal of FCPA Flash is to provide, 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 the written posts on FCPA Professor.

This FCPA Flash episode is a conversation with  Paul Pellletier, a former Principal Deputy Chief of the DOJ’s fraud section and currently a member of Mintz Levin. Pelletier has written some excellent recent pieces on the DOJ’s FCPA enforcement program (see here and here) and in the podcast he discusses the long time periods often associated with FCPA inquiries, FCPA investigative costs, and how the DOJ can best allocate its resources to fight bribery.

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FCPA “Summer School” – A Free Two-Part Webinar Series


Don’t let the dog days of summer make you lazy.

Elevate your Foreign Corrupt Practices Act knowledge and practical skills.

Recently, I conducted a two-part FCPA “summer school” series sponsored by Hiperos (a leading third-party management company).

Hundreds participated in the live webinars in July and August, but if you missed out, the webinars can be accessed at the below links.

The first webinar titled “Understanding FCPA Scrutiny and the Enforcement Landscape” provide participants with an understanding of:

  • current FCPA enforcement theories;
  • the long term and short term costs associated with an FCPA enforcement action or merely FCPA scrutiny; and
  • how the FCPA is enforced by the Department of Justice and the Securities and Exchange Commission.

The second webinar titled “FCPA Third Party Compliance Best Practices” provides participants with an understanding of:

  • the FCPA risks of utilizing third parties
  • FCPA compliance best practices relevant to third parties (including pre-engagement, engagement, and post-engagement practices) and learning from third-party compliance failures in past enforcement actions; and
  • how best to effectively communicate compliance expectations to third parties

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