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Amidst the chaos and dislocations brought about by the coronavirus epidemic, the regulators have taken a somewhat uneven approach to alleviating the burdens they impose on businesses. Certainly, they are keeping their eye out for those who might seek to take advantage of the present situation to illicit or otherwise immoral effect. Some SEC filings are off for the time being, but stress tests are on. And if you happen to be thinking that now might be a pretty good time to go about bribing some foreign officials, think again.

“Reporting and detecting misconduct continue to be very important things for companies to do,” said David Fuhr, an assistant chief of the U.S. Justice Department’s anti-foreign-bribery unit. Prosecutors are trying to be reasonable given the conditions companies face as a result of the pandemic, but “compliance has to continue,” he said….

“The mechanics of how we do our job has been affected pretty significantly,” said Robert Dodge, an assistant director of the SEC’s FCPA unit who also spoke on the webinar. But he said the agency was continuing to work.

“Nothing has been put on hold,” Mr. Dodge said. “It’s not that the rules no longer apply; the rules very much apply.”

That being said, if certain nosy compliance officers had to be temporarily redeployed away from some things to deal more pressing matters, well, people might be pretty understanding of that.

If a sanctions violation occurs during the pandemic, the Treasury said it would take the coronavirus into consideration when it assesses possible fines or other actions. It would evaluate resource issues on a case-by-case basis, according to the notice.

Antibribery Compliance Has to Continue, Officials Say [WSJ]
Treasury Says Coronavirus Impact on Compliance Could Be a Mitigating Factor in Sanctions Case [WSJ]
F.T.C. Warns 10 Companies About Virus-Related Health and Business Claims [NYT]



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Also, isn’t a $2 billion fine for ripping a country off of $6.5 billion sort of excessive, when you think about it, Attorney General Barr?


Feel Free To Filter Your Bribes Through Foreign-Government Owned Investment Banks

Bill Barr sees absolutely nothing wrong with that kind of thing.

Bill ackman beach

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Any chance he’s eligible for whistleblower money on that $123 million settlement?


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Surely the Justice Department can’t be serious about holding companies to account for all of the hundreds of illegal things they’ve done?