Last week on Corruption, Crime & Compllance, I wrote that the increase in FCPA enforcement has led to ‘mass hysteria,’ whipped up by lawyers and others.
But there’s a shortage of practical solutions, especially when it comes to gifts, meals and entertainment expenses.
In my post, I suggested an approach that is less technical and more common-sense based. ‘Negligent conduct,’ I said, ‘does not mean criminal conduct. Mistakes are not criminal.’
I hope readers of the FCPA Blog will find the post useful.
It can be found here.
Michael Volkov is the primary contributor to Corruption, Crime & Compliance. He’s a former federal prosecutor and now a partner at Mayer Brown LLP in Washington, D.C. He regularly counsels and represents clients on FCPA and UK Anti-Bribery Act issues. He can be contacted here.