The Role of Human Resources in FCPA Compliance – Part I

One sign of a mature Foreign Corrupt Practices Act (FCPA) compliance and ethics program is the extent to which a company’s Human Resources (HR) Department is involved in implementing a solution. This is the first in a multi-part series on the topic by Thomas Fox.

As We Say, Not Necessarily As We Do

The FCPA Professor Mike Koehler has a few questions for Assistant Attorney General Lanny Breuer after Tuesday's speech; in particular, how the DOJ can do so much preaching when its actions don't back up its words.

Facilitating Payments or Bribes?

As Mike Koehler explains in his latest piece, where a facilitating payment ends and where a payment to "obtain or retain business" begins is a difficult question.

Two-Tiered FCPA Justice?

As Mike Koehler points out in his latest column, the seemingly uneven treatment of big companies like Daimler, BAE, and Siemens as compared to individuals like Charles Paul Edward Jument raises the question of whether there is a two-tiered system for FCPA justice.

Jurors in William Jefferson Case Speak

In August 2009, former Congressman William Jefferson was found guilty by a federal jury of a variety of charges, but not guilty of a substantive FCPA charge. We now have some insight into why this was the case.