FCPA Professor LLC

Described as “the Wall Street Journal concerning all things FCPA-related,” and "the most authoritative source for those seeking to understand and apply the FCPA," FCPA Professor has been named a Top Law Blog for in-house counsel by Corporate Counsel, a Top 25 Business Law Blog by LexisNexis, and a top 100 Legal Blog by the American Bar Association. FCPA Professor readers include a world-wide audience of attorneys, business and compliance professionals, government agencies, scholars and students, journalists and other interested persons.

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Recently Acting Assistant Attorney General Brian Rabbitt delivered this virtual speech to a White Collar Crime workshop. As excerpted below, Rabbitt touched upon a variety of white-collar crime topics including individual accountability, DOJ policy, and data analytics. Regarding white-collar crime generally, Rabbitt stated: “[W]hite-collar crime comes in a variety of forms.  Our experience has shown us that corporate criminal activity is increasingly sophisticated and also increasingly global.  Because of this, the Criminal Division has in…
As highlighted in this prior post, in November 2018 the DOJ criminally charged former Goldman Sachs executives Tim Leissner and Ng Chong Hwa (Roger Ng) (along with Low Taek Jho – Jho Low) with Foreign Corrupt Practices Act offenses for paying bribes to various Malaysian and Abu Dhabi officials in connection with 1Malaysia Development Berhad (1MDB), Malaysia’s state-owned and state-controlled investment development company. Leissner pleaded guilty and in October Goldman Sachs resolved a net $1.66
Numerous Foreign Corrupt Practices Act enforcement actions have involved the enforcement theory that various foreign health care professionals (HCP’s) are “foreign officials” and thus occupy a status similar to a President, Prime Minister, or other traditional bona fide government official. Several of these enforcement actions have included allegations that HCP’s received speaker fees or honoraria from pharmaceutical or medical device companies. For instance, the Sanofi enforcement action included allegations that an HCP was provided “with…
[To the best of my recollection, my first introduction to the word “potpourri” was in watching Jeopardy which I was very fond of as a teenager and young adult. Rest in peace Alex Trebek] Lingo Daniel Kahn (Acting Chief of the DOJ Fraud Section) was the guest on this recent episode of the Compliance Perspectives Podcast. During the podcast, Kahn talks about COVID’s impact on DOJ enforcement and certain recent enforcement actions such as…
In recent days, Pfizer has been in the news cycle for two materially different reasons. Indeed, the juxtaposition is striking. First, Pfizer (a company that resolved an approximate $60 million Foreign Corrupt Practices Act enforcement action in 2012 concerning conduct in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia) has been under renewed FCPA scrutiny since 2019 and recently disclosed as follows: “In June 2019, we received an informal request from the U.S. Department…
Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of hundreds of professionals from around the world. In the current COVID environment, the traditional two-day, in-person FCPA Institute is not possible. However, there remains a need for FCPA knowledge and skill development and thus I am pleased to offer the FCPA Institute – Zoom on November 10-12 – an event which has already received registrations from individuals in…
This prior post highlighted the net $1.66 billion Foreign Corrupt Practices Act enforcement action against Goldman Sachs and a related entity. This prior post posed the question, based on the government’s allegations, what should happen when compliance is decent (and often good), but not great? The prior post also highlighted how the Goldman enforcement action was much different than certain other top ten FCPA enforcement actions. This prior post discussed various developments related to the…
Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of hundreds of professionals from around the world. In the current COVID environment, the traditional two-day, in-person FCPA Institute is not possible. However, there remains a need for FCPA knowledge and skill development and thus I am pleased to offer the FCPA Institute – Zoom on November 10-12 – an event which has already received registrations from individuals in…
Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of hundreds of professionals from around the world. In the current COVID environment, the traditional two-day, in-person FCPA Institute is not possible. However, there remains a need for FCPA knowledge and skill development and thus I am pleased to offer the FCPA Institute – Zoom on November 10-12. The FCPA Institute – Zoom will consist of 9 hours of integrated…
[Just when you think 2020 can’t get any more strange, there were no SEC FCPA enforcement actions during the final days of September. Why is this strange? Because as highlighted in this prior post, approximately 15% of SEC FCPA enforcement actions in recent years have occurred during the last week of September. This was the first year since 2014 that there was not an SEC FCPA enforcement action in the final days prior to…