Counterpoints …

FCPA Professor – In a recent Substack post, Richard Cassin (the former editor of the defunct FCPA Blog) writes – in reference to a June DOJ memo titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act” that “overnight, the FCPA became less about corporate graft and more about foreign policy objectives.” Cassin’s assertion overlooks that foreign policy has long been a significant theme of the FCPA.