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Video – Has The FCPA Been Successful In Achieving Its Objectives?

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As long as laws have been enacted, inquisitive minds have contemplated the salient question of whether the law has been successful in achieving its objectives. Upon the 40th anniversary of the FCPA, it is appropriate to ask the salient question of whether the FCPA has been successful.

Of course to answer this question, success in the FCPA context must first be defined. Admittedly this is no easy task, as there are various plausible meanings of success in the FCPA context.

This approximate 25 minute video discuss these various meanings of success and encourages you to answer for yourself the question of whether the FCPA has been successful in achieving its objectives.

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Free 90 Minute 2017 FCPA Year In Review Video


Thanks to Kreller Group for sponsoring my 2017 FCPA Year in Review Video.

The 90 minute video tutorial provides an overview of every corporate enforcement action in 2017; highlights notable statistics and issues to consider from 2017; discusses compliance take-away points from 2017 enforcement actions; and covers enforcement agency policy and related developments in 2017.

The free video can be downloaded here.

Friday Roundup


Quotable, SEC Annual Report, it’s called the rule of law – deal with it, across the pond, more ISO 37001 puff pieces, monitor related, for your viewing pleasure, and for the reading stack. It’s all here in the Friday roundup.


To those still hyperventilating about Foreign Corrupt Practices Act enforcement in the Trump administration (see here and here), perhaps this might calm you down. As reported here by Wall Street Journal Risk & Compliance: “[FCPA Unit Chief Daniel Kahn dismissed the suggestion that President Donald Trump‘s previous criticism of the FCPA has had any effect on the department’s enforcement of the law. Mr. Kahn said he “spanned both administrations,” referring to Mr. Trump’s predecessor, President Barack Obama, adding, “I am continuing to do what I do.”

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Friday Roundup


Selective SEC release, scrutiny alert, from the docket, for the reading stack, for your viewing pleasure, and a survey. It’s all here in the Friday roundup.

Selective SEC Release

Since it was filed in December 2011, this site has closely followed the SEC’s long-standing Foreign Corrupt Practices Act enforcement action against former Magyar Telekom executives Elek Straub (former Chairman and CEO); Andras Balogh (former Director of Central Strategic Organization); and Tamas Morvai (former Director of Business Development and Acquisitions) with various FCPA and related offenses. (See here for the prior post).

The complaint alleged, in connection with a bribery scheme in Macedonia and Montenegro, that the individuals violated or aided and abetted violations of the FCPA’s anti-bribery, books and records, and internal controls provisions; knowingly circumvented internal controls and falsified books and records; and made false statements to the company’s auditor.

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