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FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2 [Video]

This episode 30 is Part 2 of my interview with the FCPA Professor. ...more

New York Federal Court Holds SEC’s FCPA Enforcement Theory “Far Too Attenuated” For Jurisdiction

On February 19, the U.S. District Court for the Southern District of New York held that the SEC’s allegations of personal jurisdiction over a former CEO of Siemens’ Argentinian subsidiary – a German citizen with no direct...more

Limiting The FCPA’s Reach — Squaring Two Recent Decisions

You can always count on the FCPA paparazzi. When things are quiet in the FCPA world, they will take a mountain and turn it into a molehill. They have nothing better to write about; they have nothing better to focus on then...more

In What Circumstances Can Foreign Nationals Be Held Liable for Violating The Foreign Corrupt Practices Act?

In the last two weeks, in two separate SEC enforcement actions, judges in the United States District Court for the Southern District of New York issued rulings addressing when the United States Securities and Exchange...more

District Court Decision Limits the Extraterritorial Reach of the FCPA

Judge in Siemens case seeks "limiting principle" for the exercise of personal jurisdiction over foreign defendants and concludes that mere support for a bribery scheme by a foreign defendant is insufficient to establish...more

Siemens Whistleblower Complaint Underscores Need for "Top-Down" Anti-Corruption Compliance

In 2008, Siemens AG paid $800 million to settle charges that it had violated the Foreign Corrupt Practices Act, which generally prohibits bribery of foreign officials for the purpose of obtaining or retaining business. That...more

Amnesty for Armstrong? Lessons for the Compliance Practitioner

The Lance Armstrong saga continues to provide many lessons for the compliance practitioner. A recent article on ESPN.com, entitled “Lance calls for amnesty program”, reported that Armstrong has come out in favor of those who...more

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

One of the great plays and movies that I enjoy is ‘Glengarry Glen Ross’. As you might expect with anything that David Mamet pens the dialogue is absolutely spot on, fast paced and non-stop. The action generally revolves...more

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