A lawyer once used the phrase “luncheon law” in a conversation with me to describe the FCPA. What did this person mean? That the FCPA contains many vague and ambiguous terms, that there is little FCPA caselaw, and that the enforcement agencies offer little official guidance (as noted in this prior post the DOJ has promised FCPA guidance in 2012). The lawyer observed that in order to learn about the FCPA and FCPA enforcement one has to attend the luncheons during which the enforcement agency officials speak. The lawyer had a point and the “luncheon law” nature of the FCPA needs to be addressed.
‘Enforcement 40’ for 2020
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