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.
Manny Alas and Michael Skrief of PwC tackle the following: with several high-profile anti-bribery cases from 2009 now behind us, how have global corporations moved to stay ahead of this issue?
Will the economic realities of this situation lead to more plea deals over the summer? Will the cost of testing an innocence claim simply be too high such that additional defendants may raise the "white flag" of surrender?
Mike Koehler discusses Lanny Breuer's testimony before The Criminal Law Subcommittee of the Senate Judiciary Committee and outlines how Daimler, like Siemens, received cooperation credit even though disclosure of the conduct at issue was involuntarily.
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.
Mike Koehler explains why judges assigned to FCPA cases would be wise to ensure that plea agreements in FCPA cases actually serve the public interest and address the criminal conduct at issue.
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.
An FCPA trial like Frederic Bourke's is rare. An FCPA appeal is even more rare. This case is of great interest to those who follow the FCPA in that it is hoped to shed some light on the FCPA's knowledge element, and perhaps other issues as well.
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.
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.