This article, part of a continuing series of yearly analysis of Foreign Corrupt Practices Act enforcement and related developments, provides a detailed overview of quantitative and qualitative FCPA and related information and will be of value to anyone seeking to elevate their FCPA knowledge....

This article, part of a continuing series of yearly analysis of Foreign Corrupt Practices Act enforcement and related developments, provides a detailed overview of quantitative and qualitative FCPA and related information and will be of value to anyone seeking to elevate their FCPA knowledge....

The April 2018 Foreign Corrupt Practices Act enforcement action against The Dun & Bradstreet Corp. (D&B) was in many respects unremarkable. The $9.2 million settlement amount was nowhere near the top FCPA settlements and the enforcement action did not usher in any new enforcement theories....

An obvious reason to comply with the Foreign Corrupt Practices Act ("FCPA") is that non-compliance can expose a company to a criminal or civil FCPA enforcement action by the Department of Justice ("DOJ") and/or the Securities and Exchange Commission ("SEC'). However, this Article highlights that...

The Foreign Corrupt Practices Act has specific elements that must be met in order for there to be a violation. However, with increasing frequency it appears that the Department of Justice and Securities and Exchange Commission have transformed FCPA enforcement into a free-for-all corporate...

In November 2017, the Department of Justice issued a policy document titled "FCPA Corporate Enforcement Policy." Like previous DOJ FCPA efforts, the policy is "aimed at providing additional benefits to companies based on their corporate behavior once they learn of misconduct."This article grades...

Historically, the Department of Justice (“DOJ”) had two choices when a business organization was the subject of Foreign Corrupt Practices Act (“FCPA”) scrutiny: either charge the entity with an FCPA violation or not charge. However, in 2004 the DOJ brought to FCPA enforcement a third...

In recent years, Foreign Corrupt Practices Act (FCPA) enforcement has become a top priority for the U.S. government, and government enforcement officials have stated that "we in the United States are in a unique position to spread the gospel of anti-corruption" and that FCPA enforcement ensures...

An obvious reason to comply with the Foreign Corrupt Practices Act (“FCPA”) is that non-compliance can expose a company to a criminal or civil FCPA enforcement action by the Department of Justice (“DOJ”) and/or the Securities and Exchange Commission (“SEC”). However, this Article...