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This Week On FCPA Professor

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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.

This guest post highlights the U.K.’s first consideration of the Bribery Act’s adequate procedures defense.

Based on conversations I’ve had with several Foreign Corrupt Practices Act practitioners (those in law firms and those in companies), one common frustration with FCPA enforcement is the extent to which government enforcement attorneys say one thing while with the government and then say another thing  (often contradictory) when they leave the government. This flip-flop example concerning the merits of voluntary disclosure is not the only example yet represents the latest example.

This FCPA Flash podcast episode is a conversation with Gregory Paw and Sandra Orihuela regarding the broader ramifications of the Odebrecht enforcement action.

As highlighted here, yet again the Supreme Court rejected the DOJ’s overly expansive interpretation of a criminal law.

As highlighted here, Eberhard Reichert (a 78 year old German national who left Siemens in 2001) recently “pleaded guilty … to one count of conspiring to violate the anti-bribery, internal controls and books and records provisions of the Foreign Corrupt Practices Act (FCPA) and to commit wire fraud” in connection with an Argentine bribery scheme that largely occurred approximately 20 years ago.

This post rounds up other FCPA and related developments.

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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