FCPA Pilot Program leads to two 2017 declinations
The FCPA Pilot Program declinations we have seen so far in 2017 both make substantial additions to the precedent for how to avoid prosecution under the FCPA.
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Unwrapping the new FCPA Corporate Enforcement Policy
The Justice Department just announced its new FCPA Corporate Enforcement Policy. How different is it from the FCPA Pilot Program? And how will it change self-reporting misconduct?
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PremiumThe FCPA’s origin story: Why “Bribery Beyond Borders” is essential reading
I have often thought the facts of many Foreign Corrupt Practices Act (FCPA) enforcement actions would make the basis for a great series of crime-thriller books. But it turns out the origins of the FCPA itself are as dynamic, fast-paced and exciting as any such work of fiction.
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PremiumPart Two: FCPA cases closed by DOJ, SEC since January
Since the start of the Trump Administration, the Department of Justice has been winding down a number of Foreign Corrupt Practices Act investigations with little public attention. This second article further explores how and why these FCPA matters have been closed.