Tagged: FBI

The Real Explanation for the Record Year for FCPA Enforcement

I am not an “I told you so” person – frankly, it is a very unattractive character trait. I am more comfortable with the old adage – even a broken clock is correct twice a day. I fall into that category. All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record...

The DOJ’s Self-Disclosure Program Is Not Even Half the Story

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on DOJ’s recent FCPA guidance announcement.  Lauren can be reached at lconnell@volkovlaw.com.  Her bio is here.   Lots of people are talking about the DOJ’s new self-disclosure pilot program, but it was only the last of three steps announced in the DOJ’s Fraud Section FCPA Enforcement Plan and Guidance. One...