Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved. For months (and even years), we have followed this investigation and its twists and turns. Several years ago, press reports revealed an interesting piece of evidence discovered during the investigation – a spreadsheet kept...

The FCPA statute is not as vague as some contend. I remember the words of a former FTC Chairperson who told me once – “The Clayton Act is not vague. I just read the law and apply it to the facts.” Not to be too simplistic, I recognize there are legitimate disputes surrounding application of the FCPA to specific situations. As one example, I have...