All Articles
Joint DOJ-SEC Guidance On FCPA Clarifies And Confirms Agency Enforcement Attitudes And Policies
Table of Contents Introduction Lead-Up to the Guide The Guide The Legal Effect of the Guide Jurisdiction Over Foreign Entities Parent Company Liability for Actions of a Foreign Subsidiary Successor Liability Gifts and Entertainment Definition of “Foreign Official”...
Read MoreAnti-Corruption
The FCPA: 35 Years Of Evolution
Editor: Proposals to amend the FCPA have been advanced this year. What changes do you see coming in the short to medium range? Moyer: There are really two paths for change. One is legislative, as there have been calls for amendments to the FCPA. The other is guidance from the Justice Department...
Read MoreProject: Corporate Counsel Part I (Unintended Consequences) - Corporate Counsel Roundtable: The Foreign Corrupt Practices Act - Its Many Lives
Moyer: Over the last year enforcement actions under the Foreign Corrupt Practices Act - the "FCPA" - reached an all-time high. There were more cases than ever before, higher penalties than ever before, an unprecedented string of cases arising in the M&A context, and the imposition of innovative...
Read MoreProject: Corporate Counsel - Law Firms Voluntary Disclosure, Independent Compliance Monitors, nd Other FCPA Enforcement Issues
A dramatic surge in enforcement actions under the Foreign Corrupt Practices Act ("FCPA") over the last two years has highlighted a number of enforcement issues that warrant policy review. With a transition of enforcement responsibility having just occurred at both the Justice Department and the...
Read More