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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.

In this must listen FCPA Flash podcast, Ephraim Wernick (the recently departed Assistant Chief of the DOJ’s FCPA Unit) talks about the Walmart enforcement action including the imposition of a monitor, the long time periods associated with FCPA scruitny, and highlights two things about the DOJ’s FCPA unit and its enforcement program that he believes are not well understood or appreciated by the business community or FCPA bar.

This post highlights issues to consider from the Walmart enforcement action. This post describes why the Walmart enforcement action, based on the actual allegations / findings in the enforcement action, is truly underwhelming and bears little resemblance to the “bribery” and “corruption” headlines that have been written by various media outlets.

As highlighted here, in the long-standing FCPA enforcement action against Dmitry Firtash (a high-profile Ukrainian businessman) and others a judge recently denied a motion to dismiss and in doing so disagreed with the Second Circuit’s decision in Hoskins.

As highlighted here, Technip FMC joined the FCPA repeat offender club, resolved a net $81.9 million DOJ FCPA enforcement based on conduct in Brazil and Iraq, the SEC enforcement action is forthcoming, and an individual was criminally charged.

See here for yet another FCPA and related enforcement action concerning conduct in Venezuela.

As highlighted here, after a two-week trial, a federal jury convicted Joseph Baptiste and Richard Boncy of FCPA and related offenses.

Elevate your FCPA knowledge and practical skills at the FCPA Institute – Boston on October 3-4. 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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