What The 'Caldwell Doctrine' Means For FCPA Enforcement
Law360, New York (November 6, 2014, 12:12 PM EST) -- Since 2008, corporations have been hit with roughly $4 billion in fines and penalties for alleged violations of the Foreign Corrupt Practices Act. In an Oct. 23 speech at Duke Law School, Assistant Attorney General Leslie Caldwell offered a full-throated defense of the FCPA, suggesting that the U.S. Department of Justice's enforcement of the statute has not remotely reached an apex. In a passage that caught the attention of blogosphere cognoscenti, Caldwell characterized DOJ's enforcement of the FCPA as a broader foreign policy tool, rather than merely a device meant to punish and deter corporations that engage in anti-competitive overseas conduct:...
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