Learning FCPA Lessons From the Past

11/18/19: We’re often told to learn from the past. That’s what Jaclyn Jaeger, an editor with Compliance Week, helps us do in an article entitled, “Compliance Lessons from Recent Nine-Figure FCPA Settlements.” In the article, Jaeger quotes Kara Brockmeyer, former chief of the SEC Enforcement Division’s FCPA Unit to frame the evolving perspective of federal enforcement agencies...

Brockmeyer said, “It is very clear that the government’s expectations for compliance programs have evolved significantly and that their expectations are higher now than they ever have been.” Fortunately, beyond reviewing some of the largest FCPA settlements, Jaeger breaks down the violations to pinpoint significant risk areas for today’s regulated entities...