Gorman on the Origins of the FCPA
Thomas O. Gorman, who is, among other things, co-chair of Dorsey & Whitney’s Anticorruption and Foreign Corrupt Practices Act practice group, has posted The Origins of the FCPA: Lessons for Effective Compliance and Enforcement, Securities Regulation Law Journal (Spring 2015): 43-65. The “paper traces the origins of the FCPA from the early days of the Watergate hearings, through the initial SEC 'questionable payments' cases, the volunteer program and the two years of Congressional debates. From the origins of the statute the paper offers insights into crafting effective compliance today and for improving enforcement.”
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