Former Deputy AG Larry Thompson Blasts DOJ Policies
Few people have encountered the corporate criminal law enforcement (including in the FCPA context) and compliance from three vantage points: enforcer, in-house counsel, and lawyer in private practice. Larry Thompson is one of them having served as DOJ Deputy Attorney General, a lawyer in private practice, and a general counsel of a major multinational company (PepsiCo).
Thus, when Thompson speaks or writes about the Foreign Corrupt Practices Act or related topics we should pay attention.
Recently Thompson testified at a House hearing and stated that “the shared commitment [between the government and industry] to prevention and incentivizing investment in compliance is not the current reality.”