There is no private right of action under the Foreign Corrupt Practices Act (FCPA), but as I have frequently noted in prior posts, news of an anti-bribery investigation frequently is followed by a shareholder lawsuit based on allegations relating to the investigation. The latest example of this type of follow-on civil action involves the investment management firm, Och-Ziff Capital Management Group, which, according to media accounts, is the target of alleged corruption investigations.
‘Enforcement 40’ for 2020
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