The seventh grade shop teacher said, 'Always cut the wood on the way side of the line. That protects against mistakes. You can shorten a board, but you can never make it longer.'
Entries in Defenses (105)
The DOJ and SEC today released a 120-page FCPA resource guide.
Here's a note from a U.S. reader:
Dear FCPA Blog,
As noted in the Wall Street Journal, Harris Corporation is currently investigating bribery in China.
This is not its first brush with the FCPA.
Examining compliance programs of 105 publicly listed multinational companies, TI's Compliance Program Rankings rate the best and worst companies for transparency.
Jon Jordan propose his own version of an adequate procedures defense to the FCPA.
Paul Cosgrove and David Edmonds want a jury instruction about 'customary practices' in some of the countries where their employer, CCI, did business.
Payments to government employees in exchange for the performance of a non-discretionary function such as issuance of a license or a permit occur far more often than bribes to government officials in exchange for assistance in winning a government contract.
Let me be blunt: assuming the allegations to be true, had the FCPA been amended to include a good faith compliance defense, Wal-Mart would not be eligible for it.
We spoke this week with Billy Jacobson, the DOJ's former assistant chief for FCPA enforcement about his proposal that companies able to meet a five-part good-faith compliance test shouldn't face FCPA charges.