Regulations, Compliance, & Enforcement
A Look At The FCPA’s Facilitation Payments Exception
FCPA Professor - The FCPA’s legislative history teaches that in passing the FCPA, Congress intended to capture only a narrow category of payments and...
DOJ Picks Up the Pace in False Claims Act Litigation: 5 Considerations for Employers Facing Fraud Allegations
Fisher Phillips - If your company receives state-administered or federal taxpayer funds, be wary of a more focused, accelerated investigative and vetting strategy for...
One Door Closes, Another Opens: U.S. FCPA Pullback Meets the EU Anti-Corruption Directive
A&O Shearman - U.S. enforcement priorities under the Foreign Corrupt Practices Act (FCPA) have shifted following a June 2025 directive from the DOJ instructing...
A Rare Peek Into FCPA Settlement Amount Negotiations
FCPA Professor - A typical resolution vehicle for a Foreign Corrupt Practices Act enforcement action is negotiated between the company and the DOJ/SEC. Conduct...
Seventh Circuit Decision Touches Upon FCPA’s Books And Records Provision
FCPA Professor - There is little Foreign Corrupt Practices Act case law (particularly appellate court decisions), including as to the FCPA’s books and records...
Commerce Department Enforcement Actions Signal Urgent Need to Strengthen Export Control Compliance Programs
Volkov - Recent enforcement actions by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) highlight a clear and consistent message for...
It Has Been A While Since A DOJ FCPA Opinion Was Released
FCPA Professor - It has been a while since the DOJ released an FCPA opinion. The FCPA, when enacted, directed the Attorney General to...
DOJ Alleges That U.S. Defense Contractor Bribed Kurdish Official In Connection With Jet Fuel Contracts
FCPA Professor - The DOJ announced that it filed a civil forfeiture complaint in the U.S. District Court for the Central District of California...
What Detractors Keep Getting Wrong About the FCPA
Corporate Compliance Insights - Among the more common arguments against robust enforcement of the FCPA — or even against its very existence — is...
The Continuing Threat of Individual FCPA Enforcement Actions in 2026
Volkov - The final quarter of 2025 produced a modest resurgence in Foreign Corrupt Practices Act (FCPA) activity following the administration’s June 2025 FCPA...
Further Thoughts On “The FCPA Reinforcement Act”
FCPA Professor - Earlier this week, various Democratic Senators introduced a bill titled “The FCPA Reinforcement Act,” seeking to extend the statute of limitations...
Notable Criminal FCPA Enforcement Action Filed
FCPA Professor - It is one of the more dubious FCPA enforcement theories. It has never been subjected to judicial scrutiny. It is a...
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