Hats Off To Richard Grime

I recently saw that Richard Grime has retired. (See here).

As described in his law firm bio: “Prior to joining Gibson Dunn, Mr. Grime spent over nine years in the Division of Enforcement at the Securities and Exchange Commission in Washington, DC. In his last four years at the Commission he was an Assistant Director. While at the SEC, Mr. Grime supervised the filing of over 70 enforcement actions covering a wide range of the Commission’s activities. These included a series of FCPA cases, numerous accounting fraud cases involving retail, technology and financial services companies, regulated entity cases involving broker-dealers, transfer agents and investment advisers, along with multiple insider trading and Ponzi-scheme enforcement actions.”

Unlike many prior FCPA enforcement officials who leave to private practice and then offer bland commentary on FCPA issues, Grime was candid and often sharp in his critiques of DOJ/SEC FCPA enforcement.

FCPA Institute – Zoom (April 23-25)

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.

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 here, Gunvor resolved a net $474.4 million FCPA enforcement action concerning conduct in Ecuador.

The FCPA And Politics?

In recent years, Foreign Corrupt Practices Act issues have seemingly been used in attempt to score political points. (See here for a prior post with numerous examples as well as here, here and here).

In perhaps the latest example, House Judiciary Committee Chairman Jim Jordan (R-OH) and House Oversight Committee Chairman James Comer (R-KY) sent a letter to Attorney General Merrick Garland requesting certain materials the Department of Justice (DOJ) obtained during its investigation of Chi Ping “Patrick” Ho, a close business associate of Hunter Biden and the former head of an organization backed by CEFC China Energy (CEFC).”

This is Utter Nonsense . . .

A guest post today from David Simon (Foley & Lardner) regarding media coverage of Transparency International’s recent Corruption Perception Index. (See here for the prior post).

I have no desire to be a keyboard warrior or on-line troll, but this story in Law360 titled “Global Anti-Corruption Fight Is Fizzling, Study Says” is nonsense.

The Transparency International Corruption Perceptions Index is not, as the headline suggests, a “study” that suggests the “global anti-corruption fight is fizzling.”