• FCPA Prosecutions:  The Critical Role of the Accounting and Record-Keeping Provisions
  • December 19, 2011
  • Law Firm: Deming PLLC - Washington Office
  • As part of the expanding enforcement of the FCPA, the Justice Department and SEC are increasingly using the FCPA’s internal controls and recordkeeping provisions to prosecute improper payments that may otherwise be beyond the reach of the antibribery provisions.