Entries in Enforcement Policy (53)
A reader asked if there have been any FCPA cases involving small bribes -- say under $1 million. The answer is: Yes, lots of them.
The ethics & compliance community already knows we’re going to hear lots of chatter in coming months about easing the burden of compliance with the Foreign Corrupt Practices Act.
FCPA enforcement has always been bi-partisan, commanding principled support from both sides of the aisle. Is that about to change?
In the days following President-elect Donald Trump’s announcement of his intention to nominate Sullivan & Cromwell partner Jay Clayton as Chair of the Securities and Exchange Commission, countless observers have opined on how the SEC’s priorities may change in the upcoming administration.
President Elect Trump’s pick to lead the SEC is Jay Clayton. He wrote in a 2011 NYC Bar Association paper about the FCPA. The paper addressed the “lasting harm to the competitiveness of U.S. regulated companies” due to the “current anti-bribery regime.”
Since the FCPA Blog started tracking the ten biggest FCPA enforcement actions more than six years ago, most companies appearing on the list have been from outside the United States.
Assistant Attorney General Leslie Caldwell, chief of the DOJ's Criminal Division, will speak at George Washington University Law School on Thursday, November 3 at 3:00 pm.
Companies are penalized hundreds of millions of dollars for corruption. But are the penalties high compared to what the companies go on to earn?
Career prosecutor and current Deputy AG Sally Yates authored one the most important DOJ policy papers in decades -- the Yates Memo, also known as the DOJ's Individual Accountability Policy.