In this episode, I visit with Shearman & Sterling partner Philip Urofsky who leads a team which produced the 2017 FCPA Digest, one of the top annual compendium of annual FCPA reviews of the prior year’s enforcement actions and related issues. We discuss the following:
- Any trends or highlights observed in the Digest;
- How cases of Qualcomm, JPMorgan, and VimpelCom reflect new expansions of regulators’ views as to the scope of the term “anything of value” in FCPA bribery cases;
- Why the ruling in the SEC’s ongoing case against the Magyar executives upheld a novel theory on its jurisdiction to enforce the FCPA;
- His thought on the Pilot Program; is it as a success? Where might it go after this first year? Will it be renewed or made permanent? Could it be modifed?
- Do the Embraer and Odebrecht cases portend greater global anti-corruption enforcement?