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  • A Roadmap for Best Practices for Compliance Programs
    (Co-authored with Timothy Peterson)
    Thomson Reuters Westlaw (Subscription Required) | (04/02/2013)

    The recent Department of Justice and Securities and Exchange Commission guidance1 on the Foreign Corrupt Practices Act does not break new ground, but it does offer internal and external counsel, as well as ethics and compliance professionals, a user-friendly guide to the agencies’ priorities.

  • The traditional targets of the DOJ’s and SEC’s anti-corruption efforts have been companies in industries with a high degree of government interaction, such as the defense, healthcare, and extractive industries. Recent trends, however, indicate that the government has been broadening the scope of its FCPA enforcement scrutiny.