This article was reprinted with permission
from FCPA Professor
[This post is part of a periodic series
regarding "old" FCPA enforcement actions]
The year was 1982 and the Foreign Corrupt Practices Act
was nearing five years old. Up to this point, enforcement was sparse and
This is the second part of an occasional series. The first part is available here .
The entire paper will be published by Securities Regulation Law Journal early next year.
The Illicit or Foreign Payments Cases
The preliminary inquiry was followed by formal SEC investigations early in 1974....