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https://www.fdli.org/2018/11/the-responsible-corporate-officer-doctrine-protections-are-needed-despite-dojs-cautious-approach/
https://fcpablog.com/2017/02/21/sungyong-kang-the-responsible-corporate-officer-doctrine-is/
One answer is to embrace the Responsible Corporate Officer (RCO) Doctrine, at least against grand corruption. That’s because grand corruption causes serious harm to society and requires a higher level of accountability of employers. The RCO Doctrine in the United States can be traced to the U.S. Supreme Court decision in United
https://www.clm.com/fcpa-liability-and-best-practices-for-directors-and-officers/
Officers and directors may be liable for violations of the anti-bribery provisions if they are in fact the wrongdoers (engaging in, directing others to engage in, or concealing FCPA violations), or if they turn a blind eye to a wrongful payment (or pattern thereof) under the FCPA (i.e., willful blindness, deliberate ignorance, or conscious ...
https://www.lexology.com/library/detail.aspx?g=70aca93d-b65d-4b85-a783-25775b1d05bc
Officers and directors may be liable for violations of the anti-bribery provisions if they are in fact the wrongdoers (engaging in, directing others to …
https://www.jdsupra.com/legalnews/a-ceo-s-guide-to-fcpa-compliance-53070/
A CEO's Guide to FCPA Compliance. A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. CEO leadership ...
https://www.bakerlaw.com/alerts/fcpa-and-jail-are-corporate-officers-really-at-risk
On Oct. 31, James McClung, a former Louis Berger International Inc. executive, self-surrendered to the Bureau of Prisons to begin his year-and-a-day sentence for violations of the Foreign Corrupt Practices Act (FCPA).
https://fcpaprofessor.com/doj-announces-revised-fcpa-corporate-enforcement-policy/
Since 2016, the Fraud Section’s FCPA Unit has secured criminal resolutions in 17 FCPA-related corporate cases, resulting in penalties and forfeiture to the Department in excess of $1.6 billion. Of those 17 corporate criminal resolutions, only two were voluntary disclosures under the Pilot Program.
https://www.lexisnexis.com/LegalNewsRoom/corporate/b/fcpa-compliance/posts/meaning-of-quot-foreign-official-quot-under-the-fcpa
The FCPA does not define "instrumentality," and, historically, there has been little guidance on which state-owned or -controlled entities qualify as FCPA instrumentalities and therefore which of their officials and employees would be deemed foreign officials under the statute.
https://www.natlawreview.com/article/doj-unveils-revised-fcpa-corporate-enforcement-policy
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced a new U.S. Department of Justice (DOJ) enforcement policy guiding when business entities subject to the Foreign Corrupt Practices
https://www.americanbar.org/groups/business_law/publications/blt/2013/07/02_murphy/
The Guidance contains detailed legal summaries, hypothetical factual scenarios, and the DOJ and SEC views on those scenarios. While there is much of interest in the Guidance's lengthy discussion, the following nine areas are of most relevance and importance for our clients and other multinational companies: The broad reach of FCPA jurisdiction;
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