Lauren L. Valiente is an Enforcement Lawyer at Foley and Lardner, specializing in False Claims Act FCA litigation, securities fraud class actions, and shareholder derivative actions.
A company that is the subject of a U.S. government investigation under the Foreign Corrupt Practices Act FCPA will have significant incentives to cooperate with the U.S. Justice Department and, if applicable, the U.S. Securities and Exchange Commission SEC, to avoid the potential of a huge fine.
Corporate crime prosecutors and defense attorneys like to say that politics plays no role in decisions whether or not to prosecute a major American corporation. Julie O'Sullivan Georgetown Law Maybe so. But corporate power surely does play a role. And it is rarely talked about in academic circles. Last month, Georgetown Law Professor Julie O’Sullivan…