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CFTC’s New Foreign Bribery Focus Hinges on Companies’ Mea Culpas

March 11, 2019, Bloomberg Law

Laura Brookover is quoted in Bloomberg Law regarding the CFTC’s promise of no-penalty enforcement action on foreign bribery violations. Ms. Brookover says, “I think that may be the central challenge for the CFTC in rolling out this program: making sure the advisory reaches its intended audience.” Foreign companies who learn about the guidance will then have to weigh the costs and benefits of bringing themselves to the attention of U.S. regulators, particularly if they wouldn’t normally be subject to the FCPA, she said.


She adds, “It’s pretty difficult for the CFTC to find out about bribes or bribe payments misrepresented on accounting books. Given that, it makes a lot of sense that we’re seeing the CFTC really push for self-reporting in this space.”

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