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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.

Continuing with the analysis of U.S. v. Hoskins, this post highlights various big picture issues from the Second Circuit’s recent decision and this post rounds up other commentary regarding the decision.

As highlighted here, the Second Circuit recently had another FCPA appeal placed on its docket and will have the opportunity in U.S. v. Seng to construe the FCPA’s corrupt intent and obtain and retain business elements.

The SEC finally got around to bringing its portion of the Legg Mason enforcement action and this post summarizes the action based on the same core conduct alleged by the DOJ in its June enforcement action.

In this FCPA Flash podcast episode, Becky Rohr (former Principal Deputy Chief in the DOJ’s Fraud Section and current Vice President at Hewlett Packard Enterprise where she leads a team handling anti-corruption compliance in the Ethics & Compliance Office) discusses: (i) the dynamics of post-enforcement action compliance and reporting obligations; (ii) the DOJ’s suggestion in the FCPA Corporate Enforcement Policy regarding appropriate retention of business records; and (iii) her different vantage points surrounding the FCPA given her prior DOJ experience and current corporate experience.

How much do you know about the Foreign Corrupt Practices Act? Let’s find out in this week’s FCPA challenge.

Elevate your FCPA knowledge and practical skills at the FCPA Institute – Philadelphia on October 18-19. Click here to learn more and register.

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