President Elect Trump’s pick to lead the SEC is Jay Clayton. He wrote in a 2011 NYC Bar Association paper about the FCPA. The paper addressed the “lasting harm to the competitiveness of U.S.… Continue Reading
The Institute for Legal Reform — part of the U.S. Chamber of Commerce — issued a paper last week with a harsh review of the Yates Memo, also known as the DOJ’s Individual Accountability Policy
Recently one of the most unlikely sources for praise of the Foreign Corrupt Practices Act (FCPA) came out to inform us all that corporations are the cornerstone of FCPA compliance and enforcement.… Continue Reading
Miller & Chevalier’s Homer Moyer and James Tillen are among the speakers at an upcoming full-day conference called ‘The International Fight Against Corruption: Are the OECD and UN Conventions Achieving their Objectives?’… Continue Reading
As we saw in Part II, the government has come to think that the FCPA’s chief purpose is to “level the playing field.” And much criticism of modern enforcement, especially from the U.S.… Continue Reading
Late this summer, press outlets reported on anonymous claims that the Department of Justice and Securities and Exchange Commission likely would be releasing their long awaited FCPA Guidance in advance of an annual OECD Working Group on Bribery meeting on October 10, 2012.… Continue Reading
We spoke this week with Billy Jacobson, left, the former assistant chief for FCPA enforcement at the DOJ.
The former number two prosecutor in the DOJ’s FCPA unit said companies that can meet a simple five-part good-faith compliance test shouldn’t face FCPA charges.
Writing in Bloomberg’s Criminal Law Reporter on Friday, Billy Jacobson said there’s no need to amend the FCPA, as proposed by the U.S.… Continue Reading
Don’t have high hopes for change, Koehler said.
Late last year, the DOJ’s Lanny Breuer announced his intention to release new FCPA guidance during 2012.… Continue Reading