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Mike Oxley, the FCPA, and the Fight Against Terrorism

Tom Fox | January 20, 2016

Many have speculated about finding a single cause for the explosion of FCPA enforcement after 2004, including myself. The death last month of Mike Oxley, the House of Representatives sponsor of legislation known as the Sarbanes-Oxley Act of 2002 (SOX), caused me to think yet again about the variety of factors that led to this growth in enforcement.

SOX was passed in direct response to the fraud and accounting scandals perpetrated on the U.S. public by Enron, WorldCom, Adelphia, and others in the 1990s and the first decade of this century. Yet in the FCPA world, SOX is significant as well. Many have...

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