Are You a Foreign Agent? [More with McGlinchey, Ep. 21
Much has been said about the Foreign Extortion Prevention Act (“FEPA”) that President Biden signed into the law in December 2023, with particular attention given to the corrupt foreign officials who seek bribes from...more
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more
Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more
On June 4, 2018, Société Générale S.A., together with a subsidiary of the Paris-based global financial services institution, announced an agreement with both French and American authorities to resolve charges relating to...more