2019 Mid-Year Review of the Foreign Corrupt Practices Act
摘要
2019 has already seen substantial developments around compliance and several major enforcement actions arising out of the Foreign Corrupt Practices Act (“FCPA”). When the U.S. Department of Justice (“DOJ”) relaxed the “all or nothing” requirements for corporations to receive cooperation credit when identifying individuals involved in corruption allegations in late 2018, it remained to be seen how the new policy would be implemented. As we approach the midpoint of 2019, it is still too early to tell what the full ramifications of the relaxation of the cooperation requirements will be, but it is clear that the Securities and Exchange Commission and DOJ have no intention of relaxing when it comes to enforcement of the FCPA’s anti-bribery and accounting provisions. This report provides a brief overview of the FCPA, then discusses a recent revision to DOJ policy relating to the FCPA. This report also reviews a number of corporate and individual DOJ enforcement actions that have been resolved in the first half of 2019. Finally, the report notes several ongoing FCPA cases to watch in the second half of the year.
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