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 here, in a rare FCPA appellate opinion the Second Circuit rejected the DOJ’s expansive jurisdictional theory of prosecution in U.S. v. Hoskins.
As highlighted in this post, the DOJ quietly released a “declination with disgorgement” letter agreement concerning Insurance Corp. of Barbados Ltd. in which the company agreed to pay approximately $94,000 to the U.S. for alleged bribes to a Barbadian government official in exchange for insurance contracts.
The FCPA has always been a law broader than its name suggests and as highlighted here Citigroup recently resolved two FCPA books and records and internal controls enforcement actions.
As highlighted here, an FCPA related matter against Morgan Stanley was recently allowed to proceed.
As highlighted in this post, certain FCPA enforcement actions have involved – in some way – sole source procurement.
Recently, the DOJ quitely released a substantively vague so-called declination letter concerning U.K.-based Guralp Systems. However, as highlighted in this post it is difficult to analyze just what viable criminal charges against Guralp Systems the DOJ actually “declined” to prosecute.
This post rounds up other FCPA and related developments.