More Foreign Corrupt Practices Act (FCPA) Articles

Anti-Bribery

Going Mobile: In-country review tames the “border” in cross-border FCPA Discovery

MCC: The SEC and the DOJ have stepped up investigation and enforcement activities in connection with the Foreign Corrupt Practices Act (FCPA), imposing record-breaking penalties in a number of recent actions. From your perspective on the e-discovery front, what challenges do you encounter in...

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Anti-Bribery

Billion-Dollar Babies: Prosecutors go for big numbers to send a message about corruption

MCC: Companies faced record-high penalties in 2014 as a result of FCPA enforcement actions. What are companies being penalized for, and why have penalties skyrocketed? Walther: You’re correct that 2014 FCPA penalties were particularly large. Last year, FCPA penalties and disgorgement...

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Anti-Corruption

Managing Distributors and Third-Party Intermediaries: Coping with the long arm of FCPA enforcement

MCC: Starting with the basics. How do you define a “third-party intermediary”? McCann: Most companies struggle with the simple definition of a third-party intermediary (“TPI”) as they evaluate their intermediary relationship populations and the associated risks. One of...

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