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Former SEC FCPA Unit Chief Brockmeyer To FCPA Inc.


Following in the footsteps of numerous other FCPA enforcement attorneys at the DOJ and SEC who leave government service for lucrative positions in FCPA Inc., Debevoise & Plimpton announced today that Kara Brockmeyer (who last month announced she was leaving her SEC position as FCPA Unit Chief) “is joining the firm’s Washington, D.C. office as a partner and member of the White Collar & Regulatory Defense and Strategic Crisis Response and Solutions Groups.”

See this recent post for additional data points relevant to Brockmeyer’s tenure as FCPA Unit Chief.

As stated in the Debevoise release:

“For the past five and a half years, Ms. Brockmeyer directed a nationwide team of attorneys and forensic accountants investigating violations of the FCPA, including anti-bribery, books and records, and internal controls provisions of the federal securities laws.

During her tenure as chief of the unit, she oversaw many of the agency’s largest and most complex FCPA investigations, and under her leadership, the SEC increased its coordination with other countries to reach global settlement resolutions. She was also one of the principal authors of the SEC-DOJ Resource Guide to the Foreign Corrupt Practices Act, which is widely considered the definitive government-issued guide on the FCPA.”

In the release, Michael Blair (Presiding Partner at Debevoise) states:

“We are thrilled to welcome Kara to Debevoise. As someone who literally wrote the book on the FCPA, Kara’s insights and experience will afford clients an unmatched perspective, further complementing our market-leading white collar practice.”

Query what “writing the book on the FCPA” really means?

I’ve lost track how many DOJ / SEC enforcement attorneys, upon leaving government services for FCPA Inc., have claimed to be the primary author of the FCPA Guidance.

Moreover, as highlighted in this article, the FCPA Guidance is merely an advocacy piece and not a well-balanced portrayal of the FCPA as it is replete with selective information, half-truths, and, worse information that is demonstratively false. For instance, Steven Tyrrell, former chief of the DOJ fraud section stated that the guidance was “more of a scrapbook of past DOJ and SEC successes than a guide book for companies who care about playing by the rules.” (See also this prior post highlighting former Deputy Attorney General Larry Thompson’s views on the guidance.)

Andrew Ceresney (Co-Chair of the Litigation Department at Debevoise who also just recently left the SEC as Director of its Enforcement Division) states in the Debevoise release:

“As one of today’s preeminent FCPA authorities, the breadth of Kara’s knowledge is matched only by the depth of her experience. As corruption investigations are becoming truly global affairs, her experience working across borders will be invaluable to clients seeking to navigate these increasingly complex issues. Kara joins a team of talented and experienced lawyers who have handled some of the largest FCPA investigations in history, and I am very excited to work with her again and have her join our team.”

Regarding the general issue of DOJ or SEC FCPA enforcement attorneys leaving for lucrative positions with FCPA Inc. to provide defense and compliance services to business organizations subject to the enforcement climate they helped create, I have long proposed a prohibition on DOJ or SEC FCPA enforcement attorneys with supervisory and discretionary authority from providing FCPA defense or compliance services for five years upon leaving government service.

Indeed, the legitimacy and credibility of the DOJ and SEC’s entire FCPA enforcement programs hinge on this policy proposal being adopted. For additional reading on this topic, see here and here.


Brockmeyer was the SEC’s second formal FCPA Unit Chief. As highlighted in this 2011 post, the SEC’s first formal FCPA Unit Chief (Cheryl Scarboro) joined FCPA Inc. as well.

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