Day 2 of One Month to Better Compliance in Business Ventures-Key FCPA Enforcement Actions in M&A

Thomas Fox
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Today, I want to consider some of the key FCPA enforcement actions involving mergers and acquisition. These cases and the 2012 Guidance have made clear that Justice Department and SEC will vigorously prosecute companies which allow bribery and corruption to continue after a merger or purchase occurs. The key point to remember is that if a company was engaging in bribery and corruption before it was acquired and continues to do so after the transaction is completed, it is now you which is engaging in bribery and corruption, not them. See more +
Today, I want to consider some of the key FCPA enforcement actions involving mergers and acquisition. These cases and the 2012 Guidance have made clear that Justice Department and SEC will vigorously prosecute companies which allow bribery and corruption to continue after a merger or purchase occurs. The key point to remember is that if a company was engaging in bribery and corruption before it was acquired and continues to do so after the transaction is completed, it is now you which is engaging in bribery and corruption, not them.

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