Wal-Mart announced it has now spent over $300 million on FCPA compliance costs. Some FCPA watchers are so indignant by the $300 million figure they have broken it down into FCPA compliance dollars spent per day, while others imply it’s an impressive show of compliance remorse.… Continue Reading
The proceeds of FCPA enforcement actions currently go directly into the U.S. Treasury. But that need not be so. My proposed Supplemental Transparency Project would use a portion of the settlement proceeds to directly fund programs in the countries where the bribery occurred.… Continue Reading
I suggested in the last post that using the proceeds of an FCPA enforcement action to directly compensate overseas victims had been done before. And it really worked. Or I should say, it is still working, to this day.… Continue Reading
We saw in the last post that neither restitution nor disgorgement will work very well in compensating the victims of overseas corporate bribery.
But here’s something that might.
Look at what the federal enforcement agencies already do in the field of environmental law.… Continue Reading