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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, in a recent FCPA enforcement action the DOJ alleged that a company that describes itself as a “private sector business” was nevertheless an “instrumentality” of a foreign government.

As highlighted in this post, the Panama Papers served as the origins of a recent individual FCPA enforcement action alleging bribery in the Aruban telecommunications sector.

The guest in this FCPA Flash podcast episode is Adriaen Morse (among a small number of individuals who has experienced the FCPA from three different vantage points: SEC enforcement attorney, in-house counsel, and private practitioner). In the episode, Morse discusses his different FCPA vantage points including: (i) which job category of the three is the most difficult and why; and (ii) which job category of the three can best advance the objectives of the FCPA?

As discussed in this post, in guidance the FCPA enforcement agencies say that size matters and that more is expected from a large company when it comes to FCPA compliance compared to small to medium-sized companies. Yet, as highlighted in the post, does size actually matter?

As highlighted here, six years ago this week the New York Times published a front page story regarding alleged bribery in Mexico by Walmart and the post discusses what has happened since.

This post rounds up other FCPA and related developments.

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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