This Week On FCPA Professor

February 17, 2018

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.

This guest post highlights how the Global Magnitsky Act interacts with the FCPA and other corruption prevent tools.

As highlighted here, the DOJ returned to its long-standing enforcement action in connection with alleged corrupt schemes to secure contracts from Venezuela’s state-owned and state-controlled energy company PDVSA to bring additional criminal charges, including FCPA conspiracy charges against apparent “foreign officials” that seemingly conflict with legal authority. A root cause for a portion of the conduct alleged is that Venezuela was unable to pay its bills and that alleged “foreign officials” offered to pay the outstanding bills (among a stack of many no doubt) in exchange for things of value. This post highlights other enforcement actions when the government does not pay and analyzes this enforcement theory.

As highlighted here, DOJ Associate Attorney General Rachel Brand took a position at Walmart and some people seemingly hyperventilated.

How much do you know about the Foreign Corrupt Practices Act? Let’s find out in this week’s FCPA challenge.

This post rounds up other FCPA and related developments.

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