In this episode, Bruce Searby (Searby LLP and former enforcement attorney in the DOJ’s FCPA Unit) expands upon points made in an article titled “FCPA Liability for Hiring Practices Gain New Credence” including how this enforcement theory is “expansive,” how “no FCPA hiring case has been tested in court,” how in certain of the enforcement actions there are hints that the “government may struggle to establish all the elements required for an anti-bribery violation of the FCPA,” and how “building cases against individuals may be particularly challenging.”