Top Menu

Could Someone In Your Organization Benefit From A Two-Day, Active Learning Experience Devoted To The FCPA?

December 4, 2016

people thinking

Could someone in your organization benefit from a two-day, active learning experience devoted to the Foreign Corrupt Practices Act?

If so, please consider the FCPA Institute in Miami on January 12-13, 2017.

Since 2014, the FCPA Institute has elevated the FCPA knowledge and practical skills of a diverse group of professionals through active learning and I would be grateful if you could help spread word of the upcoming FCPA Institute – Miami among your contacts and colleagues.

The below video introduces you to the FCPA Institute; how the FCPA Institute is different than other FCPA conferences; the substantive knowledge and practical skills participants gain by attending the FCPA Institute; and what prior FCPA Institute “graduates” have said about their experience.

Continue Reading

SEC Director Of Enforcement Ceresney On …

December 2, 2016


Yesterday’s post highlighted comments made by Deputy Attorney General Sally Yates at a recent Foreign Corrupt Practices Act event and this post provides equal time to comments made by SEC Director of Enforcement Andrew Ceresney at the same event.

Similar to the DOJ speech, much of Ceresney’s speech represents the same old, same old something even he acknowledged during his speech.

When reading Ceresney’s comments about the importance of individual FCPA prosecutions keep in mind the following facts. In 2016 there have been 21 SEC corporate FCPA enforcement actions and 15 actions (72%) have not resulted (at least yet) in any related FCPA charges against company employees. This figure is generally consistent with the overall figure since 2008 in which approximately 80% of SEC corporate FCPA enforcement actions have not resulted in any related FCPA charges against company employees.

Continue Reading

Same Old, Same Old From The DOJ On Individual FCPA Prosecutions

December 1, 2016


In running a Foreign Corrupt Practices Act news source for seven years running, there is a “been there, done that” aspect to some of the writing.

For instance, every late November FCPA Professor highlights speeches by DOJ and SEC enforcement officials at a certain FCPA conference run by a for-profit conference company which engages in the disgraceful practice of marketing our public officials to draw attendance to its paid event as if the public officials are a commodity they own. (See here, here, and here for prior posts regarding this practice).

Why DOJ and SEC officials allow themselves to be used in such a way is beyond me.

Continue Reading

FCPA Flash – A Conversation With Professor Juliet Sorensen

November 30, 2016

FCPA Flash

The FCPA Flash podcast provides 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 Professor Juliet Sorensen (Northwestern Pritzker School of Law and a former prosecutor in the U.S. Attorney’s Office in Chicago). Professor Sorensen, along with her co-author David Hoffman (Sidley Austin) recently published a book titled “Public Corruption and the Law.”

In the podcast, Sorensen discusses: (i) the many gray areas when it comes to bribery and corruption; (ii) whether the FCPA, as it nears its 40th year, has been successful in achieving its objectives; (iii) how FCPA enforcement can be improved; and (iv) other forms of corruption outside the FCPA context.

Continue Reading

FCPA Professor Named A Top 100 Law Blog

November 29, 2016


Editors of the ABA Journal announced yesterday they have selected FCPA Professor as one of the top 100 best blogs for a legal audience.

As noted in the ABA Journal’s release:

“Law professor Mike Koehler’s ‘coverage of the U.S. and global enforcement of anti-bribery laws is unsurpassed in its breadth and depth,’ writes Warren Faure, senior environmental counsel at Sun Chemical Corp. Robert Wilhelm, a legal editor at Bloomberg BNA, writes that the blog ‘doesn’t just give lip service to DOJ press releases. Koehler goes behind the rhetoric and digs into the actual nuts and bolts of [Foreign Corrupt Practices Act] prosecutions.’

Continue Reading