Ordinarily, companies are in a defensive position when it comes to the FCPA. However, the act is increasingly being used “offensively” to achieve a business objective or to further advance a litigating position…
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Does The DOJ Really Believe That A Significant Percentage Of Issuers Are Engaged In Criminal Acts?
June 6, 2013
Survey: Only 30% of respondents say their companies always conduct a risk review of existing business relationships and ties to agents in foreign countries.
Like Siemens, SNC-Lavalin Creates Employee Amnesty Program
May 30, 2013
SNC-Lavalin is mired in a bribery and corruption scandal — and earlier this week announced ”a company-wide Amnesty Program to encourage current employees to report potential corruption and anti-competition matters.”
Marketing the FCPA and the FCPA Risks Of, Well, Just About Everything
May 17, 2013
Marketing of the FCPA is indeed a topic worthy of exploration and this post profiles recent FCPA marketing activity…
Seeing The Light From The “Dark Ages”
May 8, 2013
It seems like DOJ is clearly troubled, with good reason, by traditional notions of corporate criminal liability…
Former BizJet Executives Charged / Sentenced
April 9, 2013
If the DOJ’s rhetoric of holding individuals accountable in the context of corporate resolutions is to mean anything, the BizJet corporate action was one where related individual enforcement actions were to be expected…
Lanny Breuer And Foreign Corrupt Practices Act Enforcement
March 29, 2013
While much of the public scrutiny of Breuer and his Criminal Division focused on the financial services industry, the substantive law of most interest to Breuer appeared to be the Foreign Corrupt Practices Act.
Foreign Corrupt Practices Act: The Guidance Continues to Baffle
March 14, 2013
The portions of the Guidance that can accurately be described as guidance represent little new information to those previously knowledgeable about the FCPA and its enforcement.
The Most Extensive Collection Of FCPA Scholarship Between Two Covers
March 5, 2013
A reading list compiled as part of “The FCPA At Thirty-Five and Its Impact on Global Business,” a full-day symposium at The Ohio State University.
Deposition Prep That Lead To One Of The Most Notable FCPA Cases
February 22, 2013
FCPA enforcement actions can also originate in other interesting and unique ways. The 2001-2002 enforcement action against David Kay and Douglas Murphy is an instructive example.
