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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 in this post, Dun & Bradstreet resolved a $9.2 million SEC FCPA enforcement action based on conduct of two indirect Chinese subsidiaries from 6-12 years ago.

This post highlights the many troubling or notable issues to consider from the enforcement action. In connection with the SEC’s enforcement action, the DOJ quietly released a so-called “declination” letter stating that it has “declined prosecution consistent with the FCPA Corporate Enforcement Policy.”

Yet this post asks:  based on information in the public domain what viable criminal charges against D&B did the DOJ actually “decline”? The answer appears to be none.

This FCPA Flash episode is a conversation with Jason Prince (Holland & Hart who offices in Boise and Washington, D.C.). During the podcast, Prince discusses: (i) FCPA issues for companies in the Rocky Mountain West; (ii) the similarities and differences between FCPA compliance and compliance with other export or international trade regulations; and (iii) how former Idaho Senator Frank Church (who was instrumental in crafting the FCPA) might think about the modern era of FCPA enforcement.

This post reboots a long-standing FCPA proposal, this time in the aftermath of a recent disclosure by Millicom.

As highlighted in this post, FCPA “fake” news and false information is rampant.

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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