In The News

Top FCPA Enforcers Discuss Evolving and Diverging Enforcement Approaches and the Defense Bar Responds

The FCPA Report

02 Dec 2015

James Koukios, former Senior Deputy Chief of the Department of Justice Criminal Division Fraud Section and partner in the firm’s Securities Litigation, Enforcement & White-Collar Defense Practice Group, commented on the “Year in Review” panel by the heads of the DOJ and SEC FPCA Units at the 2015 ACI FCPA Conference in Washington, D.C. Mr. Koukios stated that “companies should not get a false sense of security” from DOJ’s new policy of emphasizing “bigger” corporate actions and cases against individuals because this does not represent a shift in DOJ’s “willingness to aggressively investigate FCPA cases.” He emphasized the importance of compliance programs because “you do not want your company to be on the wrong end of a ‘big’ resolution.” He also discussed the increased likelihood of investigations by multiple jurisdictions and the increasing sophistication of whistleblowers.

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