The Crystal Ball for Future FCPA Prosecutions for Internal Controls Violations (Part IV of IV)
The FCPA crystal ball is constantly shifting. Sometimes patterns emerge and trends become evident. FCPA enforcement is fairly consistent with occasional blips. What becomes trend setting often becomes the new norm. Just look at the changes in Schedule C, and the compliance program requirements. Look at the Schedule Cs from five years ago, and compare them to the Schedule Cs used now. There have...