In this episode, I visit with Sherman & Sterling partner Phillip Urofsky who leads a team which produced the the 2017 FCPA Digest, one of the top annual compendium of annual FCPA reviews of the prior year's enforcement actions and related issues. We discuss the following:
- Any trends or highlights that observed in the Digest;
- How cases of Qualcomm, JPMorgan, and VimpelCom reflect new expansions of regulators’ views as to the scope of the term “anything of value” in FCPA bribery cases;
- Why the ruling in the SEC’s ongoing case against the Magyar executives upheld a novel theory on the Commission’s jurisdiction to enforce the FCPA;
- His thought on the Pilot Program; is it as a success? Where might it go after this first year? Will it be renewed or made permanent?
- Do the Embraer and Odebrecht cases portend greater global anti-corruption enforcement?