“Resources Reflect Policy” and Other Observations
Michael Volkov discusses themes emerging in the DOJ’s and SEC’s enforcement of FCPA violations thus far in 2018.
There are two distinct themes in FCPA enforcement: The first is consistency (i.e., that some enforcement actions are relatively consistent across the board), and, in the last five to 10 years, the FCPA caseload has been fairly steady; the second is variability, meaning that new policies have an impact on FCPA enforcement. Some minor and some major. All of this may be another in my series of…
