R. Christopher Cook  and Stephanie Connor Jones Day provide some more insight into an article I had posted about earlier regarding the DOJ’s renewed interest in going after pharmaceuticals fro FCPA violations.  Note you do have to register to get this article, but it takes less than two minutes, and they very rarely spam your email account.

From Mondaq.com:

Enforcement of the Foreign Corrupt Practices Act (“FCPA”) continued to grow last week. On Thursday, November 12, a senior Department of Justice (“DOJ”) official predicted increased scrutiny of the pharmaceutical industry under the FCPA. A day later, prosecutors obtained a 13-year sentence for a former U.S. Congressman convicted of conspiring to violate the law. These and other developments highlight important questions regarding the standard by which knowledge under the FCPA will be measured. If the DOJ continues to take the position that a mere failure to investigate possible bribery can give rise to FCPA liability, then businesses will face heightened risks in their overseas operations…