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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.

As highlighted here, it is “earnings management” season at the SEC.

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The Percentage Of Corporate DOJ And SEC FCPA Enforcement Actions That Result From A Voluntary Disclosure

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For at least 15 years the government has encouraged business organizations to voluntary disclosure conduct that violates the Foreign Corrupt Practices Act.

In more recent years, in 2012 the government sought in the FCPA Guidance to entice business organizations to voluntarily disclose by, among other things, highlighting six “anonymized examples of matters DOJ and SEC have declined to pursue” where a common thread was voluntary disclosure. In April 2016, it was the DOJ’s pilot program, an effort – in the words of the DOJ –  to “encourage voluntary corporate self-disclosure.” Thereafter, it was the November 2017 DOJ FCPA Corporate Enforcement policy which – in the words of the DOJ – was intended to provide “guidance and greater certainty for companies struggling with the question of whether to make voluntary disclosures of wrongdoing…”

But what do the numbers show? What percentage of DOJ and SEC enforcement actions are the result of a voluntary disclosure? The below post provides the answers.

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How A Successful Football Organization Can Inform FCPA Compliance In A Business Organization

FB

Granted football this Fall may not be as widespread as previous years because of COVID.

However, games have begun and for Foreign Corrupt Practices Act (and related) professionals, understanding the game is not just a professional diversion, but one that can actually add professional value as well. The reason is because understanding what makes a football organization successful can also inform FCPA compliance in a business organization.

In the spirit of the season, my article “How a Successful Football Organization Can Inform FCPA Compliance In a Business Organization” highlights four attributes of a successful football organization that can also elevate FCPA compliance in a business organization.

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Elevate Your FCPA Knowledge And Practical Skills With The FCPA Institute Online

InstituteOnline

The FCPA Institute Online is the most comprehensive online FCPA training course available and is a time and cost efficient way for in-house and outside counsel; compliance professionals; finance, accounting, and auditing professionals; business executives and others to elevate their FCPA knowledge and practical skills.

The FCPA Institute Online consists of over 12 hours of narrated instruction from Professor Koehler (as well as availability to answer questions) and guides professionals through the following FCPA topics in an integrated and cohesive manner.

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