When is an FCPA Enforcement Action Not About Foreign Corrupt Practices?
Mike Koehler argues that, despite the FCPA's focus on foreign bribery, most enforcement actions brought under it—“enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions”—have nothing to do with foreign bribery.
🔒 Members Only · Compliance & Enforcement BriefYou’ve reached the member portion of this brief.Members read the full analysis and the source documents in every Brief, six days a week.