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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 highlighted here, Vitol recently resolved a net $90 million FCPA enforcement action for conduct in Brazil, Ecuador and Mexico.

As highlighted here, the DOJ recently filed a response brief to a motion to dismiss an FCPA indictment and in doing so set forth its internal controls theory of enforcement. This post further examines the DOJ’s brief by questioning a case the DOJ cited.

This guest post discusses SEC so-called “obey-the-law” injunctions.

As highlighted here, the recent OECD Report on U.S. FCPA enforcement nicely captures why comparing FCPA enforcement to other nation’s enforcement of “FCPA-like laws” is absurd.

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