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The Government’s Response to the Proposed Affirmative FCPA Compliance Defense

At the recent ACI 2012 National Conference on the U.S. Foreign Corrupt Practices Act, the U.S. Government provided a direct response to the U.S. Chamber of Commerce’s affirmative compliance defense proposal. Over the last two years, since the Chamber issued its proposed amendments to the FCPA, the Chamber has advocated for “a defense that would […]

Author: Matteson Ellis

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Business Pushback against Brazil Foreign Bribery Bill

In January 2012, FCPAméricas reported on how Brazil is currently considering an overhaul of its foreign bribery law (see Another BRIC in the Anti-Corruption Wall). In March, we reported on how a special committee created by the Brazilian Congress to analyze the bill made revisions to the draft that bolstered certain provisions (see Road to […]

Author: Matteson Ellis

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Why Secretary Clinton’s FCPA Remarks Are Notable

On March 22nd, U.S. Secretary of State Hillary Clinton, speaking on behalf of the Obama administration, forcefully joined the debate on whether FCPA-related burdens should be reduced. In her remarks at Transparency International-USA’s Annual Integrity Award Dinner, where she accepted the award as an international leader in anti-corruption advocacy in government, business, and development assistance, […]

Author: Matteson Ellis

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If FCPA Enforcement Says It, Believe It

FCPA enforcers take a lot of heat. The U.S. Chamber of Commerce is not exactly their friend. Commentators like Tom Fox rightly call for more information on declinations. But there is one thing with which you cannot argue. When FCPA enforcement says it, you should believe it. I recently came across my notes from the November 2007 […]

Author: Matteson Ellis

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What FCPA Enforcement Is Thinking in 2011

The annual National Conference on the U.S. Foreign Corrupt Practices Act (FCPA) in Washington, DC, hosted by American Conference Institute, is always a unique opportunity to hear from FCPA enforcement officials about what they are currently thinking. This year’s meeting did not disappoint. Held last week, it included noteworthy statements, some of which are provided […]

Author: Matteson Ellis

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