Sections 922-924 of the Dodd-Frank financial reform bill have the potential to impact FCPA enforcement because it creates new whistleblower provisions applicable to all securities laws violations and the FCPA is part of the Securities and Exchange Act of 1934.
No, I'm not "happy" with the outcome of either the financial reform legislation or SEC v. Goldman Sachs. I'm a cynic, and, to that extent, let's just say that my worst fears have come to full realization.
Corporate compliance, difficult in the best of times, presents even more challenges in an economic downturn. This article by Mark Srere sets forth the top five challenges that a company’s compliance department may face in 2010.