FCPA Professor – The recent Scoular Company FCPA enforcement action was a “garden variety” enforcement action. A company doing business in a foreign country had a point of contact with a “foreign official” in connection with some regulatory aspect of its business and a bribe was allegedly paid. FCPA enforcement actions in connection with licenses, permits, inspections, customs, or other regulatory issues are very common including prior enforcement actions involving Mexico. For instance, in 2023 Lifecore resolved an FCPA enforcement action in connection with wastewater discharge permits in Mexico.

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