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Entries in Strict Liability (3)


New anti-corruption regulation reaffirms Brazil’s focus on prevention

Sao Paulo, Brazil - March 15, 2015: Protesters marching on Paulista Avenue against government corruption.On March 18, Brazil’s president Dilma Rousseff issued a decree that clarifies and facilitates enforcement of the country’s main tool against corporate bribery, the 2013 Clean Companies Act (“CCA”). This regulation was highly anticipated and came at a sensitive time, just a few days after massive protests against the government, and in the middle of a snowballing scandal at Petrobras that led to the first (or first high-profile) CCA enforcement actions.

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Tom Fox: Disgorgement could become a remedy for FCPA strict liability

A trend emerged in the fall of 2014 of FCPA enforcement actions by the SEC but where the Department of Justice either declined to prosecute the company or settled via a non-prosecution agreement.

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Are FCPA books and records and internal controls defenses becoming obsolete?

Many of us scratched our head in 2010 when the Oracle FCPA enforcement action came out. We didn't understand how a company could be prosecuted, even civilly by the SEC for internal controls or book and records violations, without evidence that bribes had been paid. But after the past few months, I think Oracle was a precursor to a strict liability standard that's coming to FCPA enforcement.

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