Tagged: DOJ FCPA enforcement

2018 FCPA Year in Review: The More Things Change, The More They Stay the Same

Happy New Year! Another year is in the books for FCPA enforcement and compliance.  The headline for this past year (like many other years) is/was – The more things change, the more they stay the same. FCPA enforcement is bipartisan and immune from political winds.  I may live to regret this assertion.  Whether DOJ is under Republican or Democrat control, FCPA enforcement will continue.  DOJ’s...

Four Current FCPA Enforcement Trends

There are two distinct themes in FCPA enforcement – the first is consistency, i.e., that some enforcement actions are relatively consistent across the board and, in the last five to ten years, the FCPA caseload has been fairly steady; the second is variability, meaning that new policies have an impact on FCPA enforcement.  Some minor and some major.  All of this may be another in...