Foreign Corrupt Practices Act Statistics, Theories, Policies, and Beyond

53 Pages Posted: 24 Apr 2016  

Mike Koehler

Southern Illinois University School of Law

Date Written: April 21, 2016

Abstract

The Foreign Corrupt Practices Act is not a new law, it was enacted in 1977. Nevertheless, 2015 was a commemorative year as it marked the fifth anniversary of the Department of Justice declaring a “new era” of FCPA enforcement; the fifth anniversary of Congressional FCPA reform hearings; and the third anniversary of the Department of Justice and Securities and Exchange Commission issuing FCPA guidance. In addition to these mileposts, 2015 was also a notable year in several other respects and that is the focus of this article.

This article, part of an annual series, paints a picture of FCPA and related developments from 2015. Specifically, this article dissects FCPA enforcement in a number of ways and highlights meaningful statistics from 2015 as well as historical comparisons. Thereafter, this article discusses a range of noteworthy issues from 2015 such as: expansive and evolving FCPA enforcement theories; judicial scrutiny of FCPA and related enforcement theories; policy pronouncements and developments relevant to FCPA issues; and developments beyond the FCPA that nevertheless touch upon FCPA issues or are otherwise relevant to a similar space.

Keywords: FCPA, Foreign Corrupt Practices Act

Suggested Citation

Koehler, Mike, Foreign Corrupt Practices Act Statistics, Theories, Policies, and Beyond (April 21, 2016). Cleveland State Law Review, Vol. 56, 2016, Forthcoming. Available at SSRN: https://ssrn.com/abstract=2768267

Mike Koehler (Contact Author)

Southern Illinois University School of Law ( email )

1150 Douglas Drive
Carbondale, IL 62901-6804
United States

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