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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Latest from FCPA Professor LLC

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FCPA Professor has been 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.” Set forth below are the topics discussed this week on FCPA Professor – a week largely devoted to 2019 year in review posts. This post highlights the alleged “foreign officials” from 2019 corporate DOJ and SEC FCPA enforcement actions. This post highlights certain facts and figures concerning the…
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If the Foreign Corrupt Practices Act is an area of your practice or interest, this post may make you feel like a kid in a candy store. FCPA Professor has been the place to visit this month for in-depth 2019 FCPA enforcement statistics as well as comparisons to historical statistics. If you missed the daily posts, no worries. This post consolidates in one place the statistics recently published on FCPA Professor. This post highlights the…
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These pages have covered Donald Trump and the Foreign Corrupt Practices Act since 2012 (see here) and long before he was President (see here and here). Days after Trump was elected President in November 2016, this post was titled “Let’s All Take a Deep Breath When It Comes To FCPA Enforcement In The Trump Administration.” When there was not a corporate FCPA enforcement action during the (better sit down for this one –…
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These pages have covered Donald Trump and the Foreign Corrupt Practices Act since 2012 (see here) and long before he was President (see here and here). Days after Trump was elected President in November 2016, this post was titled “Let’s All Take a Deep Breath When It Comes To FCPA Enforcement In The Trump Administration.” When there was not a corporate FCPA enforcement action during the (better sit down for this one –…
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This post highlighted certain facts and figures regarding the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act offenses in 2019 and historically. As highlighted in the prior post, DOJ FCPA individual enforcement actions are significantly skewed by a small handful of enforcement actions and the reality is, despite the DOJ’s rhetoric, approximately 80% of DOJ corporate enforcement actions since 2006 have not (at least yet) resulted in any related DOJ FCPA charges against company employees. Another very interesting…
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This recent post focused on SEC individual FCPA actions in 2019 and historically. Today’s post highlights certain facts and figures concerning the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act violations in 2019 and historically. The key word above is FCPA violations. Some in the FCPA space include enforcement actions containing non-FCPA charges (often money laundering charges against alleged “foreign officials”) related to an FCPA enforcement action as an individual FCPA enforcement action. While it is…
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A “foreign official.” Without one, there can be no FCPA anti-bribery violation (civil or criminal).  Who were the alleged “foreign officials” of 2019? This post highlights the alleged “foreign officials” from 2019 corporate DOJ and SEC FCPA enforcement actions. There were 14 core FCPA enforcement actions in 2019. Of the 14 actions, 8 (57%) involved, in whole or in part, employees of alleged state-owned or state-controlled entities (“SOEs). By way of comparison: in 2018, 53% of…
FCPA Professor has been 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.” Set forth below are the topics discussed this week on FCPA Professor – a week largely devoted to 2019 year in review posts. This FCPA Flash podcast episode concerns 2019 FCPA and related developments. This post summarizes DOJ FCPA enforcement in 2019 against business organizations. This guest …
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Convicted, sentenced, to FCPA Inc. and for the reading stack. It’s all here in the Friday Roundup. Convicted As noted in this DOJ release: “[Donville Inniss] a former member of the Barbados Parliament, who also served as the Minister of Industry of Barbados, was found guilty [of two counts of money laundering and one count of conspiracy to commit money laundering] by a federal jury for his role in a scheme to launder bribes…
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As highlighted in this post, like prior years (see here, here and here) much of the largeness of 2019 FCPA enforcement resulted from corporate enforcement actions against foreign companies. Specifically, of the 14 corporate Foreign Corrupt Practices Act enforcement actions in 2019, 8 (57%) were against foreign companies (based in many instances on mere listing of securities on U.S. markets or in a few instances on sparse allegations of a U.S. nexus in furtherance…