Mike Koehler: That the FCPA is a fundamentally sound statute does not mean that FCPA enforcement is fundamentally sound. I, along with many others, have serious concerns about FCPA enforcement across a wide spectrum. On one end, many enforcement theories seem to be contrary to the intent of Congress in passing the FCPA and indeed, in certain cases, contrary to the statute itself. On the other end, the most egregious instances of corporate bribery are resolved without FCPA anti-bribery charges.
‘Enforcement 40’ for 2020
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