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"Resources Reflect Policy" and Other Observations Michael Volkov discusses themes emerging in the DOJ’s and SEC’s enforcement of FCPA violations thus far in 2018. There are two distinct themes in FCPA enforcement: The first is consistency (i.e., that some enforcement...

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Costs can balloon quickly in FCPA investigations, however, these investigations don’t have to spin out of fiscal control. Corporate counsel can and should get to the root of alleged violations – certainly before the government does – without “boiling the ocean” to unearth the facts and decimating the organization’s bottom line. Based on Roscoe, Michael and Pat’s...

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