FCPA Enforcement: Where Have All the Enforcement Actions Gone?
With major FCPA investigations in the works, some of us are on pins and needles waiting for the enforcement actions ...
Tag: Tone at the Top
More Empty Words for an FCPA Compliance Defense
Most compliance practitioners recognize that the FCPA compliance defense issue is very much a thing of the past, though some ...
Pro Football and the FCPA Professor
Ah, September: bringer of fall, sweater weather, and football. Compliance practitioners and lovers of football alike can appreciate the parallels ...
The Illusion of No Victims: The Final Component of “Rationalizing Bribery”
For some professionals engaged in corrupt behavior, often the rationale behind their impropriety is that no one is being hurt. ...
FCPA Mid-Year Assessments
Despite what the various FCPA mid-year assessments are saying, FCPA enforcement is not on the wane. It's here to stay, ...
Coolness in Being the Bad Guy? Eli Wallach and GSK
GlaxoSmithKline has gotten plenty of negative attention lately for allegations of widespread corruption in its China operations, accusations that may ...
Five Ways that Concentration of Wealth and Power Affects Corruption Risk in Latin America
Latin America is known for high levels of corruption, but what's driving corruption in the region? The main culprit is ...
The Next Frontier in International Anti-Corruption Enforcement
Anti-corruption enforcement is evolving, and significant challenges lie ahead. FCPA expert Matteson Ellis presents three issues compliance professionals are likely ...
Esquenazi, Part 2: the Test for Determining an Instrumentality Under the FCPA
An in-depth analysis of the recent decision by the 11th Circuit Court of Appeals, with a handy guide to determine ...
FCPA Compliance for SMEs: How Smaller Companies Meet Enforcement Agency Expectations
Small- and medium-sized enterprises (SMEs) are as subject to FCPA regulations as their much larger counterparts, but how they apply ...
Common Sense in the Definition of “Instrumentality” Under the FCPA
An opinion released Friday by the Court of Appeals offers some much needed clarity on just what organizations are considered ...
Criminal FCPA Cases – Targeting Individuals
If the past is any indicator (and it normally is), the DOJ will continue to step up enforcement against individuals. ...
