Speeches by Foreign Corrupt Practices Act enforcement officials have long included over-the-top rhetoric. (See this article for a general summary).
This recent post highlighted a speech by DOJ Deputy Assistant Attorney General Matthew Miner. In the speech, Miner stated that when a company voluntarily discloses FCPA issues and engages in remedial actions, this frees up DOJ resources and “these resources can then be directed to other cases, not only in the FCPA context, but also to other areas such as opioid enforcement, human trafficking, and crimes impacting vulnerable victims, like children and the elderly.”
The DOJ’s latest FCPA rhetoric does not even pass the smell test and set forth below are various reactions to this portion of Miner’s speech from FCPA practitioners.