Tagged: Supervisory personnel accountability

FCPA Remediation Focus on Supervisory Personnel

The Justice Department’s FCPA enforcement and remediation focus on supervisory personnel is an interesting development. On the one hand, DOJ has been slow to bring individual criminal enforcement actions for FCPA violations. At the same time, they are flirting with a potential new enforcement approach – a criminal prosecution for circumventing internal controls without proof of bribery. However, FCPA prosecutors appear to be gun-shy after...