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Thomas Gorman

In this episode, Thomas Gorman (Dorsey & Whitney and former Senior Counsel in the SEC’s Division of Enforcement) discusses the SEC's recent report of investigation relevant to the FCPA's internal controls provisions, whether certain emerging FCPA issues could have been addressed through a report of investigation as opposed to an enforcement action, and common SEC enforcement theories including the "prevent and detect" standard not even found in the FCPA.

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