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.
There is not a “lull” in FCPA enforcement as some have claimed. But this post assumes – for argument’s sake – that there is and asks why is this a bad thing?
SEC Commissioner Hester Peirce continues to object to various aspects of a large majority of FCPA enforcement actions. (See here).
As highlighted here, despite rhetoric from the SEC that it is focused on individual enforcement in the FCPA context and otherwise, the gap in SEC FCPA enforcement is now over three years.
This post provides factual data relevant to the DOJ’s “virtuous cycle” for what happens after voluntary disclosures.
