Jon Jordan Renews the Call for a Compliance Defense to the FCPA

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We recently saw the entry of a new voice for the addition of a compliance defense as an amendment to the Foreign Corrupt Practices Act (FCPA). This voice was Jon Jordan, Senior Investigations Counsel with the US Securities and Exchange Commission’s (SEC) FCPA Unit, a national unit within the SEC specializing exclusively on FCPA and foreign bribery matters. Jon’s ideas appeared in a law review article, entitled “The Adequate Procedures Defense Under the UK Bribery Act: A British Idea for the Foreign Corrupt Practices Act” found in Volume 17, No. 1, Fall 2011 edition of the Stanford Journal of Law, Business & Finance.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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