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Foreign Corrupt Practices Act (FCPA) Strict Liability

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

White & Case LLP

Does your compliance program address UK exposure?

White & Case LLP on

Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2015 Developments and Predictions for 2016

WilmerHale on

I. Introduction: Enforcement Trends and Priorities - Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II

In this episode which is Part II of my look at SEC enforcement of the FCPA, I consider whether profit disgorgement is available to the SEC in a strict liability enforcement action of violation of internal controls. ...more

Thomas Fox - Compliance Evangelist

Miss Marple Short Stories and SEC Enforcement of the FCPA, Part V – Final Thoughts

I conclude my week of exploration of Agatha Christie’s Miss Marple short stories and the Securities and Exchange Commission’s (SEC) enforcement of the Foreign Corrupt Practices Act (FCPA) by reviewing some of the new things...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 138, Tribute to Mr. Spock and Strict Liability for Internal Controls Under the FCPA

In this episode, I pay tribute to Leonard Nimoy and his immortal character Mr. Spock. I also discuss that the SEC may be moving towards a strict liability standard for internal controls under the FCPA....more

Thomas Fox - Compliance Evangelist

Is Strict Liability Coming to FCPA Enforcement?

I think that a strict liability standard is coming to Foreign Corrupt Practices Act (FCPA) enforcement. A number of factors have caused me to come to this conclusion. While there may well be wide disagreement as to whether...more

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