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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 here, 60% of SEC FCPA enforcement actions in recent years do not involve charges or findings that an issuer violated the anti-bribery provisions.

A component of FCPA compliance is for a business organization to communicate its unique risks and its specific policies and procedures throughout its organization in a way that resonates with the intended audience. However, this post demonstrates how NOT to communicate FCPA compliance.

As highlighted here, compliance professionals should once again take Transparency International’s Corruption Perception Index with a grain of salt.

In light of four recent SEC enforcement actions concerning the internal controls provisions in which civil penalties were all below $200,000 this post highlights the SEC’s troubling inconsistent enforcement approach.

This post rounds up other recent FCPA developments.

Elevate your FCPA knowledge and practical skills at the FCPA Institute – Nashville on April 11-12. CLE credit is available. Can’t attend the live, in-person FCPA Institute? No problem, the FCPA Institute is also online and is the most comprehensive online FCPA training course available.

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