FCPA Enforcement Actions Reach Beyond Bribery and Accounting Tricks to Facilitate It

Mike Koehler notes that the scope of the FCPA extends beyond foreign bribery and the books and records that might implicate such schemes, arguing that most enforcement actions based on the books-and-records and internal controls provision “have nothing to do with foreign bribery and these provisions are among the most generic legal provisions one can possibly find.” In this article, he examines the $12.5 million civil action taken against Synchronoss Technologies, Inc.