In the Episode, I visit with James Koukios, a partner at Morrison and Foerster in Washington DC. Koukios is a former prosecutor from the Department of Justice who worked in the FCPA Unit. He is back to discuss the firm’s monthly newsletter the Top 10 International Anti-Corruption Developments for October 2019.

Some of the highlights include:

  • The DOJ Issues Guidance on Corporate Inability-to-Pay Claims. We consider is this something new or codification of prior practices?
  • The Unaoil guilty pleas. Are they huge, even bigger than Panalpina?
  • The EU whistleblower initiative. Is this a sea change or something else? What might it mean for anticorruption enforcement?
  • OECD Expresses Concern over Brazil’s Foreign Bribery Enforcement. Has there been a change in Brazil enforcement or is this simply a part of the natural ebb and flow of enforcement actions?
  • Are things really going to heat up in Mexico in terms of investigations involving Pemex? Should US companies which have done business in Mexico be scrubbing their operations?


To see the firm’s Top 10 International Anti-Corruption Developments for October 2019, click here.