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The FCPA And Compliance In The Classroom

FCPA in the Classroom

This recent FCPA Blog post suggested “law schools, as far as we know, haven’t caught on to the great employment prospects for compliance professionals” and that “aside from a few isolated examples, the concept of training students to be compliance officers hasn’t taken root in the law schools’ curricula.”

In the heartland, at Southern Illinois University School of Law, the FCPA and compliance skills are  part of the educational experience.  I have been teaching for two years a specific course I developed regarding the Foreign Corrupt Practices Act, FCPA enforcement and FCPA compliance.  It is one of the only law school courses of its kind in the country.  (See here for media coverage of the class).

The learning objectives for the course include the following:

  • understanding the events and policy reasons that motivated Congress to enact the FCPA and what Congress intended to capture in enacting the FCPA;
  • appreciating the root causes of why companies often become the subject of FCPA scrutiny as well as the typical origins of FCPA enforcement actions;
  • gaining a comprehensive understanding of the FCPA’s anti-bribery provisions and books and records and internal controls provisions, including the ability to identify legal risk through real-world issue-spotting videos;
  • understanding the FCPA’s many ripples such as how actual FCPA enforcement actions brought by the Department of Justice and/or the Securities Exchange Commission are often just one consequence of FCPA scrutiny or enforcement, as well as exploring other negative legal and financial consequences that often result from FCPA scrutiny or enforcement;
  • going beyond the FCPA and understanding other U.S. laws (such as the Travel Act) and certain foreign laws (such as the U.K. Bribery Act) relevant to conducting business in the global marketplace;
  • gaining practical FCPA compliance skills including the ability to conduct an FCPA risk assessment and to develop FCPA compliance policies tailored to unique risk profiles;
  • gaining insight into FCPA Inc. as a niche and vibrant industry full of career opportunities;
  • analyzing various other legal and policy issues associated with the FCPA, FCPA enforcement and FCPA compliance;
  • assessing whether the FCPA and FCPA enforcement policies are best achieving the objectives of the FCPA or whether FCPA reform is warranted.

While the course is about a specific statute, its enforcement, and compliance strategies, learning objectives also include:

  • how business organizations operate in the global marketplace and various realities of the global marketplace; and
  • DOJ and SEC enforcement policies and resolution vehicles relevant to both business organizations and individuals including related resolution dynamics.

During the course, students engage with FCPA practitioners and in-house counsel with FCPA and other compliance responsibilities.

In terms of assessing accomplishment of the learning objectives, students prepare client memos on a specific FCPA enforcement action and the capstone writing assignment for the class is conducting a comprehensive risk assessment of a real company and suggesting pro-active compliance policies and procedures designed to minimize risk.

In short, the FCPA and compliance is being taught in the classroom and I am confident in saying that the students who have taken the above class know more about the FCPA, FCPA enforcement and FCPA compliance than most any other law students in America.

I encourage anyone looking for FCPA and compliance talent to give these students an opportunity to put these skills to use.  If you are interested in connecting with my students for internship or job opportunities, please e-mail me at

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