Voluntary Disclosure, Independent Compliance Monitors, And Other FCPA Enforcement Issues

The Metropolitan Corporate Counsel
06.15.05
Commenting on FCPA enforcement issues, Homer Moyer writes that a dramatic surge in enforcement actions under the Foreign Corrupt Practices Act (FCPA) over the last two years has highlighted a number of enforcement issues that warrant policy review. With a transition of enforcement responsibility having just occurred at both the Justice Department and the Securities and Exchange Commission, a fresh look at how this 28-year old law is administered and enforced is timely.
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