Tagged: Third-Party Intermediaries

SAP’s Bribery Schemes — Systemic Corruption Around the Globe (Part II of III)

When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts.  Some would argue that DOJ has been consistent all along.  The truth, like most issues, lies somewhere between the extremes.  With lots of fanfare, DOJ implemented a new Corporate Enforcement Program to udnerscore its intent to examine the criminal and civil enforcement history of corporate defendants when considering an appropriate penalty.  This...