Our Africa Anti-Corruption Practice has previously outlined key considerations for handling internal investigations and remediation of compliance issues in Africa. Here, we take a closer look at a particular aspect of remediation, the root cause analysis. After the dust settles on an investigation identifying misconduct, a root cause analysis can serve as the most effective
Jennifer Saperstein practices in the areas of civil and criminal litigation and white collar defense and investigations, with a focus on anti-corruption issues and insurance coverage litigation. She regularly advises clients on anti-corruption laws, including the Foreign Corrupt Practices Act. She has conducted multiple internal investigations in connection with potential violations of the Foreign Corrupt Practices Act, and advises clients on the creation and implementation of anti-corruption compliance programs. Ms. Saperstein also assists companies and private equity firms with anti-corruption due diligence reviews related to acquisitions.
Beyond The FCPA: New U.S. Regulator Enforcing Against Foreign Corruption
Yet another U.S. regulator is entering the foreign corruption space. The Commodity Futures Trading Commission is a civil agency that oversees commodity and derivatives markets in the United States. It enforces the Commodity Exchange Act, a set of statutes that are enforced criminally by the U.S. Department of Justice. The CFTC has authority to impose…