Potential New FCPA Enforcement Targets Come Into Focus

By David Chaiken and Kurt Wolfe (February 26, 2019, 4:04 PM EST) -- Recent revelations of a Foreign Corrupt Practices Act investigation into Major League Baseball, as well as statements from FCPA enforcement authorities, indicate that the U.S. Department of Justice and the U.S. Securities and Exchange Commission are employing a flexible, outside-the-box approach to FCPA enforcement, increasingly focusing on nontraditional targets and industries.

Indeed, in remarks at a November 2018 conference, the chief of the SEC's FCPA enforcement unit suggested that the agency is scrutinizing industries that are not traditional FCPA enforcement targets, noting that "you are seeing some additional industries come to the front as far as getting enforcement action," and "[t]here...

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