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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.

See here for a new article titled “Foreign Corrupt Practices Statistics, Qualitative Issues, and Other Developments.”

As discussed here, there is a correlation between a country’s Global Peace Index ranking and its Corruption Perception Index ranking.

As highlighted in this post, in releasing the 2016 FCPA Pilot Program and thereafter in 2017 in releasing the FCPA Corporate Enforcement Policy, the DOJ stated that a “main goal” was to encourage voluntary disclosures to permit prosecution of individuals. Yet, nearly five years later there have been FCPA prosecutions of individuals in only 7% of cases the DOJ has self-identified as being resolved pursuant to / or consistent with the Pilot Program or the CEP.

As highlighted in this post, it has been approximately five years since the DOJ released the so-called “Yates Memo” – a policy document in which the DOJ renewed its commitment to individual accountability for corporate wrongdoing. However, in the FCPA context there have been fewer individual enforcement actions connected to corporate enforcement actions since the Yates Memo compared to prior.

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