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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.

Make your voice heard regarding Canada’s quest for deferred prosecution agreements. This post highlights my submission to the Government of Canada by highlighting that Canada’s justifications for DPAs are based on assumptions about DPAs in the U.S. that lack evidence or assumptions undermined by actual evidence.

The FCPA Guidance turned 5 this week. This post looks back at the Guidance and the facts and circumstances which surrounded its issuance.

As discussed here, the recent FCPA enforcement action against Antony Mace (the former CEO of SBM Offshore) is a must read for all executive officers.

As discussed in this post, because of the frequent double-dipping dynamic in FCPA enforcement actions against issuers, Deputy AG Rosenstein’s concern about multiple law enforcement and regulatory agencies pursing a single entity for the same conduct is very much FCPA relevant.

As highlighted here, Wal-Mart’s long-standing FCPA scrutiny appears to be headed towards a $283 million resolution. Yet, that is not the real story. The real story is that Wal-Mart has spent close to $900 million on pre-enforcement action professional fees and expenses and compliance enhancements.

This post rounds up other FCPA and related developments.

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