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Disclosure and Negotiating with the Government – A FCPA Conundrum?-Part I

All compliance programs are designed to prevent, detect and deter ethical violations. In the United States, they are also designed to bring companies into compliance with the Foreign Corrupt Practices Act (FCPA). However, as important as these programs are, it is equally important for a company to...

Disclosure and Negotiating with the Government – A FCPA Conundrum?-Part II

In yesterday's blog we explored the question of whether a company should self-report a potential FCPA violation to the pertinent US governmental authorities. Today, conclude our two-part series by exploring three issues: (1) What should you disclose; (2) How/When Should you Disclose; and (3)...

Reports Just In: Invasions from Mars and the UK Bribery Act

On this day 75 years ago Orson Welles caused a nationwide panic with his broadcast of “ War of the Worlds ” – a realistic radio dramatization of a Martian invasion of Earth. The show began on Sunday, October 30, at 8 pm. A voice announced: “The Columbia Broadcasting System and...

Louis Berger International and Two Former Employees Resolve Enforcement Action

This article was reprinted with permission from FCPA Professor Last Friday, the DOJ announced the second corporate Foreign Corrupt Practices Act enforcement action of 2015. It was against Louis Berger International Inc. (LBI, a New Jersey-based infrastructure and development company) and focused...

Issues to Consider From the Louis Berger Enforcement Action

This article was reprinted with permission from FCPA Professor This recent post highlighted the DOJ FCPA enforcement action against Louis Berger International (LBI) and two former employees. This post continues the analysis by highlighting various issues to consider from the enforcement action...