Buying an FCPA Violation: Successor Liability is Alive and Well
FCPA commentators enjoy spending their time picking through the bodies of FCPA enforcement actions for trends and patterns. Sometimes trends are evident and sometimes they are not. One clear picture from FCPA enforcement in 2011 is that successor liability continues to flourish. FCPA practitioners use the shorthand for this enforcement risk – “buying an FCPA violation.” The Justice Department and the SEC have held acquiring...