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Former DOJ FCPA Unit Chiefs Speak

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Some think – or at least I’ve been told – that certain of my Foreign Corrupt Practices Act views are controversial or out of the “main stream” (whatever the “main stream” actually is or means).

For instance, recently I was a guest on a podcast (publication forthcoming) about FCPA enforcement activity and was told I have a “different” view than some on the amount of enforcement activity in recent years. I really didn’t know what to say other than that my views are factual and based on real data (see here for instance).

Regardless and more broadly, one of the interesting things about writing about the FCPA and related issues on a daily basis is that often a former FCPA enforcement official says the same thing about issues I was writing about years prior.

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Stay Ahead Of The Curve

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One reason to read FCPA Professor is to stay ahead of the curve and to learn about issues others will be focused on in the weeks and months ahead.

For instance, this January 19th post highlighted a disclosure by Calavo Growers, Inc. “a global leader in quality produce, including avocados, tomatoes and papayas, and a pioneer of healthy fresh-cut fruit, vegetables and prepared foods.”

Although the disclosure did not mention the Foreign Corrupt Practices Act, the post surmised that the disclosure was likely FCPA related given that a recent FCPA enforcement action concerned a guacamole manufacturing plant in Mexico. The post mentioned that, in certain instances, when one company resolves an FCPA enforcement action based on a certain issue in a specific country, it then leads to scrutiny of other companies in the same industry operating in the same country.

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DOJ Seeks New FCPA Unit Chief

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As highlighted here, following a typical career path, the DOJ’s FCPA Unit Chief recently departed for private practice.

The job was recently posted and applicants should have “at least 5 years of federal prosecution experience; have experience investigating and prosecuting FCPA matters; have supervisory experience; and have experience working investigations with foreign authorities.”

Other “preferred qualifications” include:

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Former Assistant Attorney General Of DOJ Criminal Division Joins Law Firm

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Kenneth Polite became the Assistant Attorney General for the DOJ’s Criminal Division in early 2021.

During his tenure, Polite announced “important revisions to [the DOJ’s] Corporate Enforcement Policy, which applies to all corporate criminal matters handled by the Criminal Division, including all FCPA cases nationwide.” (See here for the prior post).

As stated by Polite,  “these revisions provide specific, additional incentives to companies for voluntary self-disclosures, as well as for cooperation and remediation and “make clear that there will be very different outcomes for companies that do not self-disclose, meaningfully cooperate with our investigations, or remediate.”

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