FCPA Flash – The Official Podcast of FCPA Professor
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In this episode, James Noe (special counsel with Jones Walker who previously served in various in-house counsel and executive roles with various oil and gas companies) discusses: the easiest and most difficult aspects of FCPA compliance in the oil and gas industry; the extent of facilitating payments in the industry; whether oil and gas companies are too risk averse when it comes to FCPA issues; and civil actions by industry participants when losing business because of a refusal to make bribe payments.
In this episode, Philip Urofsky (Shearman & Sterling and a former FCPA enforcement official at the DOJ) elaborates on various issues such as jurisdiction over foreign actors and parent-subsidiary issues found in the firm’s always informative FCPA Digest. Urofsky also opines on what the FCPA enforcement landscape might look like if business organizations would put the government to its burden of proof in enforcement actions.