FCPAméricas Blog

Archive for Business Purpose category:

What FCPA Enforcement is Thinking in 2013

What is the current thinking of FCPA enforcement officials at the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC)? At ACI’s 30th International Conference on the FCPA this year, two top officials provided insights (they clarified that their statements reflected their own views and not the views of their respective agencies). […]

Author: Matteson Ellis

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Understanding the FCPA — Where Lawyers Go for Guidance

On my last trip to Latin America, attorneys asked me how they could learn more about the FCPA from primary sources. Like most of us, they regularly receive alerts and notices from law firms, accounting firms, investigation outfits, and consultants. They read the blogs, including FCPAméricas. And they see press articles (people are still talking […]

Author: Matteson Ellis

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Risky Business: The Unexpectedly Broad Application of the FCPA’s Business Purpose Element

Today’s blog post is also cross-posted on the Click4Compliance Blog. Companies and individuals subject to the U.S. Foreign Corrupt Practices Act (FCPA) often misunderstand the scope of subject activity. They assume that bribes are illegal only if they relate to a company’s core business. As a result, they might focus anti-corruption compliance efforts in areas […]

Author: Matteson Ellis

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