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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, approximately 70% of SEC corporate FCPA enforcement actions over the past several years have involved foreign companies.

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Questions To Ponder

questions to ask

Do “many business leaders now appreciate that the FCPA offers them a measure of protection against foreign corruption.”?

This is a direct quote from the State Department’s recently released “National Action Plan on Responsible Business Conduct.” (See here).

There is no citation for this assertion and query what “measure of protection” even means?

The full context of the assertion is the following paragraph in the National Action Plan on Responsible Business Conduct.

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FCPA Institute – Zoom (April 23-25)

FCPA Institute - Zoom

Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of professionals from around the world. The FCPA Institute began as an in-person event, but shifted to Zoom in 2020. The Zoom event is time and cost efficient and has resulted in greater participation from professionals from around the world.

The next FCPA Institute – Zoom will be offered on April 23-25 and consists of 9 hours of integrated and cohesive instruction (each day from 8:30-11:30 central) led by Professor Koehler, an FCPA expert with FCPA practice and teaching experience.

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Unraveling The Many Enforcement Actions Against Various Commodities Trading Companies And Individuals


A few hours after the DOJ announced a March 28th Foreign Corrupt Practices Act action against Trafigura (see here and here for prior posts) the DOJ also announced (what was increasingly becoming obvious over the last few years) that “its long-running investigation into international commodities trading companies that paid bribes to win business with state-owned and state-controlled oil companies in Latin America and Africa has resulted in six corporate resolutions, 20 convictions of individuals, and total fines, forfeitures, and other penalties of more than $1.7 billion.”

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Let’s Analyze This For A Bit

© ClassicStock / Masterfile
Model Release: Yes
Property Release: No

This recent Wall Street Journal article titled “DOJ Uncovering More Misconduct Through Self-Disclosure Program, Says Top Official” begins:

“More companies are choosing to voluntarily disclose misconduct to prosecutors after a policy revision last year that increased the potential benefits of doing so, a top Justice Department official said.

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