This article appeared in Business Crimes Bulletin, an ALM publication covering financial and white-collar crime. For Corporate Counsel, Litigators, Managing Partners, Defense Attorneys. Visit the website to learn more.


Editor’s note: In last month’s newsletter (see http://bit.ly/2q2ZSo5), the authors began discussion of whether we should expect changes in enforcement of the Foreign Corrupt Practices Act (FCPA) in the Trump era. Trump once called application of the law to deals done in countries where bribery is the cultural norm “absolutely crazy.” But that was when he was purely a businessman, and a private citizen. What about now?