It is September which means enforcement agency officials hit the “conference circuit” to give scripted speeches.
Last week it was DOJ Principal Deputy Assistant Attorney General Nicole Argentieri delivering a speech to a corporate compliance audience in New York (see here for the prior post), yesterday it was Argentieri delivering a speech to a corporate compliance
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement
Recently Gurbir Grewal (the SEC’s Director of the Division of Enforcement) delivered this speech titled “The Five Principles of Effective Cooperation in SEC Investigations” at a securities law conference.
This post summarizes the speech and provides factual information and rebuttal points relevant to certain topics.
Grewal began as follows:
“This event … offers regulators like me a