A Conversation with Michael Levy Regarding The SEC’s “Unlawful” Enforcement Of The FCPA’s Accounting Provisions

In an interview with FCPA Professor, Michael Levy, a partner at Paul Hastings, discusses recent enforcement actions in which the SEC expanded the FCPA’s books and records and internal controls provisions in an “unlawful” manner and in a way that gives the SEC “capacious authority to regulate by enforcement almost any aspect of the operations of any issuer.” During the podcast, Levy elaborates on these issues and provides suggestions for how SEC enforcement can get back on track given that no issuer has ever put the SEC to its burden of proof in the FCPA’s 40-year history.