FCPA Compliance Report-Episode 456, James Koukios on the MoFo September International Anti-Corruption Newsletter

16 Dec 2019

Morrison and Foerster partner James Koukios breaks down the Top 10 International Anti-Corruption Developments for September 2019 in this episode. Highlights include:

  • What are the key takeaways from three fiscal year-ending FCPA enforcement actions from the SEC?
  • Restitution is becoming for a bigger topic in FCPA settlements. What is restitution in the FCPA context? Why the different rulings in Och-Ziff and PetroEcuador? Should companies start to consider this in settlement negotiations?
  • SEC Chair laments perceived lack of international anti-corruption enforcement efforts – what is (or was) going on?


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