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 highlighted in this post, in a statutory interpretation case that was very similar to the statutory interpretation issues in the “foreign official” challenge, the Supreme Court reminded us that the law means what actual words in a specific statute say (not what other similar statutes may say) and not what the SEC interprets words in a statute to mean.
While certain commentators may think otherwise, this post highlights that bribery and corruption allegations are frequently used as the basis for civil litigation and it would be nice if commentators engaged in a bit of research before hitting the publish button and polluting the internet with false and misleading information.
This post once again reboots a long-standing FCPA proposal, this time in the aftermath of a recent disclosure by Teradata. The proposal is this: when a company voluntarily discloses an FCPA internal investigation to the DOJ and/or SEC and when one or both of the enforcement agencies do not bring an enforcement action, have the enforcement agency publicly state, in a thorough and transparent manner, the facts the company disclosed and why the enforcement agency did not bring an enforcement action based on those facts.
News flash – Canadian businesses prefer less harsh criminal sanctions and other observations relevant to Canada’s movement towards DPAs. (See here).
This time of year is heavy on annual reports and other corporate disclosures and this post rounds up various scrutiny alerts and updates.
How much do you know about the Foreign Corrupt Practices Act? Let’s find out in this week’s FCPA challenge.
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