Koehler on the FCPA

Mike Koehler has posted Ten Seldom Discussed Foreign Corrupt Practices Act Facts that You Need to Know on SSRN with the following abstract:

Much is written about the Foreign Corrupt Practices Act. However, amid the clutter of enforcement agency rhetoric and resolution documents not subjected to any meaningful judicial scrutiny as well as the mountains of FCPA Inc. marketing material touting the next compliance risk, there are certain FCPA facts that are seldom discussed.

Yet such facts, covering the entire span of the FCPA — from the statute’s enactment, to its statutory provisions, to FCPA enforcement, to FCPA reform, to the FCPA industry itself — occasionally bear repeating.

This article does that by highlighting ten seldom discussed FCPA facts that you need to know.