In this episode I visit with Morrison and Foerster partner James Koukios on the firm’s January and February Top Ten international anti-corruption cases, issues and developments. In this episode we discuss the following:

  1. PDVSA and related indictments/issues/enforcement actions and the push from the business community to attack corruption from the demand side, as opposed to a FCPA-supply side.
  2. In February 2018, two FCPA-related civil RICO suits were filed. While FCPA-related plaintiff suits are increasingly common, they more often take the form of shareholder derivative actions or securities fraud class actions. What are the implications if any for the compliance professional?
  3. The implications of Digital Realty Trust from the (former) DOJer perspective.This decision may well be a mixed bag for companies with a short term win translating into long-term negative consequences.
  4. Canadian DPA initiative and the working relationship between anti-bribery prosecutors in the US and Canada.
  5. Petrobras shareholder settlement-outlier or harbinger of things to come. We explore if the unique set of facts led to the settlement or will it mean more and similar actions.
  6. Declinations in January and February-what if anything do they communicate to the compliance practitioner, particularly in light of the new FCPA Corporate Enforcement Policy announced by the Justice Department in late 2017.

For further reading see the Morrison and Foerster, Top Ten International Anti-Corruption Developments for January 2018 and Top Ten International Anti-Corruption Developments for February 2018

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