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.
The SEC (like the DOJ) often talks about the importance of individual FCPA enforcement actions. However, as highlighted in this post it’s been over a year since the SEC has brought an individual FCPA enforcement action. More broadly, since 2016 the SEC has brought 13 corporate enforcement actions and just 1 (7%) involved related SEC charges against a company employee.
This post highlights how the DOJ’s latest FCPA rhetoric doesn’t even pass the smell test.
There is a common narrative in certain circles that the FCPA was dormant for its first 20-25 years. However, as highlighted in this post it is a fallacy.
As highlighted here, in the case that keeps on giving, the DOJ announced additional charges in the PDVSA bribery action.
This post rounds up other FCPA or related developments.