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This And That

Today’s post is short on written words, but long on content.

Recently, I had the pleasure to return to the Foreign Corrupt Practices Act Compliance and Ethics Report series run by Tox Fox.

Part 1 of the discussion (approximately 25 minutes) focuses on recent speeches by DOJ and SEC officials concerning the FCPA, or issues relevant to FCPA enforcement (see here, here, and here for prior posts), as well as Judge Rakoff’s recent speech (see here) in which he called certain DOJ enforcement policies “both technically and morally suspect.”

Part 2 of the discussion (also approximately 25 minutes) focuses on how trade distortions and barriers often serve as the root cause of many FCPA enforcement actions (see here), how FCPA settlement amounts have come a long way in a short amount of time (see here), and various survey data collected from students in my FCPA class at Southern Illinois University School of Law (see here).

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