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This Week On FCPA Professor


FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

As highlighted in this post, the first corporate FCPA enforcement action of 2018 was against Elbit Imaging. The enforcement action concerned conduct between 2006 and 2012 (beyond any conceivable statute of limitations) and without admitting or denying the SEC’s findings Elbit agreed to pay $500,000 (an amount reflective of the fact that Elbit is currently winding down its operations).

Efforts by the U.S. government to combat foreign corruption are broader than just the Foreign Corrupt Practices Act. For instance, approximately ten years ago the DOJ announced a Kleptocracy Asset Recovery Initiative and related to this general program this post highlights a bill recently introduced in Congress “to authorize the Secretary of the Treasury to pay rewards under an asset recovery rewards program to help identify and recover stolen assets linked to foreign government corruption and the proceeds of such corruption hidden behind complex financial structures in the United States and abroad.”

Matt Miner recently became Deputy Assistant Attorney General in the DOJ’s criminal division and this post highlights his previous writings on topics now relevant to this job ranging from the “Yates Memo,” DOJ transparency, the deficiencies of DOJ guidance as a solution, and the FCPA’s “foreign official” element.

As highlighted in this post, the DOJ once again returned to a Russia nuclear bribery scheme to bring an enforcement action against Transport Logistics International which resolved the matter by agreeing to pay $2 million (reduced from $21.4 million based on inability to pay).

In this guest post, ISO 37001 is revisited.

How much do you know about the Foreign Corrupt Practices Act? Let’s find out in this week’s FCPA challenge.

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