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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.

Numerous FCPA enforcement actions have involved abuse of employee reimbursements. However, the recent Herbalife enforcement action is in a league of its own and represents employee reimbursements gone wild.

As discussed here, in the recent Herbalife enforcement action the government failed to present the “complete picture” regarding the company’s internal audit function.

As highlighted in this post, in connection with an initial public offering, a company disclosed FCPA scrutiny.

Some things written about the FCPA and related topics in recent years are nothing short of bewildering. In certain instances, there seems to be little understanding of context and little regard for actual facts. See here for a recent example concerning monitors.

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