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 post addresses the difficult issue of how to evaluate the effectiveness of a compliance program – difficult because of what legal authority (as well enforcement agency guidance) actually say vs. seemingly conflicting actual FCPA enforcement actions and enforcement agency double-speak.
As highlighted here, Uncle Sam collected $25.2 million in an FCPA enforcement action based on allegations that foreign subsidiaries of French pharmaceutical company Sanofi bribes Kazakh and Middle Eastern “foreign officials.” This post analyzes additional issues to consider from the enforcement action.
As highlighted here, in sentencing Joo Hyun Bahn to 6 months in prison for violating the FCPA, a judge rejected the DOJ’s 70-87 month sentence recommendation. Also, the SEC brought an enforcement against Bahn based on the same core conduct alleged by the DOJ’s previous enforcement action.
This post rounds up other FCPA and related developments.