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Browse: Home / 2015 / March / 05 / Is Strict Liability Coming to FCPA Enforcement? | FCPA Compliance and Ethics Blog

Is Strict Liability Coming to FCPA Enforcement? | FCPA Compliance and Ethics Blog

By Securities Docket on March 5, 2015, 10:00 am

I do not think this strict liability standard is coming for criminal enforcement of the FCPA by the Department of Justice (DOJ) because there is still a requirement of intent under the Act. Intent can be inferred by conscious indifference but I still do not think that day of reckoning is near for DOJ enforcement. However I do think that a confluence of events, FCPA enforcement actions by the Securities and Exchange Commission (SEC) and statements by the SEC representatives, all point towards a new enforcement angle to the FCPA. I think that the SEC is moving towards a strict liability standard for internal controls under the FCPA….

via Is Strict Liability Coming to FCPA Enforcement? | FCPA Compliance and Ethics Blog

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Posted in SEC, Top | Tagged FCPA, Strict Liability

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