This article was reprinted with permission
from FCPA Professor
Lanny Breuer stepped down as Assistant Attorney General
of the Justice Department's Criminal Division on March 1st after nearly
four years on the job. Word of Breuer's departure began circulating soon
after the airing of a PBS Frontline program that examined the general lack of
prosecutions of Wall Street executives in the aftermath of the so-called
financial crisis. While much of the public scrutiny of Breuer and his
Criminal Division focused on the financial services industry, the substantive
law of most interest to Breuer appeared to be the Foreign Corrupt Practices
Act. This article examines FCPA enforcement and related issues during Breuer's
tenure, demonstrates that his tenure was not as glowing as DOJ suggests, and
shows that FCPA enforcement under Breuer raised significant public policy
issues that need to be addressed by his successor.
So begins my article "Lanny Breuer and Foreign Corrupt
Practices Act Enforcement" recently published by Bloomberg BNA's White Collar
Crime Report. (The article can be downloaded here).
Interested in analyzing Breuer's public
FCPA statements and assessing the performance of his Criminal Division
against such statements? Breuer's FCPA speeches can be found here,
Read more articles on the FCPA by Mike
Koehler at FCPA
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