• Cocktails,  FCPA

    Foreign Corruption, Pilot Program, Aviation Cocktail

    The Republic is now a year out from DOJ’s announcement that its Foreign Corrupt Practices Act “pilot program”  was to be made permanent.  Some would say that the anniversary calls for alcohol either in joy or in sorrow.  Perhaps an old cocktail, recently revived?  One consistent with the “pilot” theme?  Let’s try the Aviation: Drink in hand, you can sit down and read  FCPA Compliance 1 Year After DOJ Revised Policy by my Lightfoot colleagues Brandon Essig, Tenley Armstrong, and Jeff Doss (and me): Because of the risks, the dollars and the players, the FCPA connotes sophistication to the point of mystery and complexity to the point of opacity. We propose that…