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New Proposal For FCPA ‘Adequate Procedures’ Defense

Jon Jordan, a friend of the FCPA Blog, has just published a new article in the Stanford Journal of Law, Business & Finance.

It discusses the adequate procedures defense under the UK Bribery Act and explores suggestions for a similar kind of compliance procedures defense under the FCPA. 

In the article, Jordan propose his own version of a compliance procedures defense. He then provides his ‘Eleven Commandments for an Effective FCPA Compliance Program’ — minimum procedures he believes should be included in any FCPA compliance program, both to avoid offenses and for using a proposed compliance procedures defense.
Jordan knows his subject. He’s a Senior Investigations Counsel with the U.S. Securities and Exchange Commission’s Foreign Corrupt Practices Act Unit, a national unit within the SEC specializing exclusively on FCPA and foreign bribery matters.

The article comes with a caveat that we’ll repeat: The Securities and Exchange, as a matter of policy, disclaims responsibility for any private publication or statement by any of its employees. The views expressed in the article are those of the author and do not necessarily reflect the views of the SEC, the SEC’s FCPA Unit, or any of the author’s other colleagues on the staff of the SEC.

Jon Jordan’s article — ‘The Adequate Procedures Defense Under the UK Bribery Act: A British Idea for the Foreign Corrupt Practices Act’ — can be downloaded as a pdf (2.2MB) here.

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