Tagged: FCPA Year in Review

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...

Episode 19 — 2017 FCPA Year in Review

FCPA enforcement continued in 2017 with an increased emphasis on individual enforcement. Despite early questions as to the new administration’s commitment to FCPA enforcement, the Justice Department and the SEC continued to push aggressive enforcement cases, building on well-established relationships with global law enforcement partners. In a significant development, the Justice Department issued a new FCPA Corporate Enforcement Policy, which created a declination presumption for...