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.
The DOJ’s Deputy Attorney General delivered a speech and talked about individual accountability, prior misconduct, monitors, and NPAs and DPAs. Substantively the speech was largely a yawner and the policy changes articulated are marginal at best and elevate form over substance.
As highlighted here, a former DOJ Fraud Section Chief questions whether the DOJ policy pronouncements may deter corporate voluntary disclosures.
Stericycle Inc. has been under FCPA scrutiny since 2017 and recently disclosed a $61 million accrual for enforcement actions (see here).
This post laughs out loud at certain portions of SEC Chair Gensler’s recent speech.
A trade association in the United Kingdom releases a white paper of the meaning of “public official.”
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