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This Week On FCPA Professor


FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

As discussed in this post, the Supreme Court has agreed to hear another SEC disgorgement case. Although not an FCPA matter, the decision could have a meaningful impact on the SEC’s frequent disgorgement remedy in FCPA enforcement actions.

As highlighted here, VEON (formerly known as VimpelCom) recently emerged from a deferred prosecution agreement in connection with its 2016 Foreign Corrupt Practices Act enforcement action concerning conduct in Uzbekistan.

This post checks in on the absurd voluntary disclosure Lennox International made in 2016.

Given that FCPA enforcement actions comprise a minuscule percentage of the SEC’s overall enforcement program, this post asks: does the SEC even need a specific FCPA unit?

This post discusses an example of the so-called “trial penalty” in an FCPA enforcement action. Speaking of which, in a long-standing FCPA enforcement action, Lawrence Hoskins was found guilty at trial of FCPA and related offenses. (See here).

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