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.
This FCPA Flash podcast episode is a conversation with Robert Luskin regarding FCPA enforcement actions against foreign companies.
As highlighted here, in connection with the 2016 FCPA enforcement action against Embraer the DOJ announced an enforcement action against former Embraer executive Colin Steven. As highlighted here, Keppel Offshore & Marine resolved a net $105.5 million FCPA enforcement action based on various Brazil bribery schemes.
This guest post rounds up bribery and corruption developments in Australia.
As noted in this guest post, “acceding to an SEC request for a tolling agreement is often a one-way bargain – the SEC can continue its investigation at a languid pace, and the individual or entity is not given any real benefit, except the continued specter of living under a lengthy investigation, the timing of which is solely in the hands of the government.”
A few weeks ago the DOJ announced a new “FCPA Corporate Enforcement Policy.” This article grades the new policy and addresses the following issues: (i) the obvious logical gap in the Corporate Enforcement Policy (CEP); (ii) how the CEP, both in terms of rhetoric and substance, is really nothing new; (iii) ten specific reasons why the corporate community should take the CEP with a grain of salt; and (iv) how the CEP falls short of accomplishing the laudable goals articulated by the DOJ compared to other alternatives previously advanced.
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