SEC Director Khuzami's Remarks about the FCPA, Good Behavior, Indifferent Behavior and Bad Behavior
The Director of the SEC's Division of Enforcement, Robert Khuzami, delivered remarks during news briefing about the SEC-DOJ FCPA Guide. According to Director Khuzami, the SEC should reward companies that adopt compliance programs which are effective in preventing violations, and the SEC is not going after the "$5 cup of coffee, or the one-off $50 gift to a public official . . . but payments of real and substantial value that clearly represent an unambiguous intent to bribe a foreign official to obtain or retain business."
View remarks in full here (links externally to SEC website).See also: Yesterday's news - SEC and Justice Department Release Resource Guide to the U.S. FCPA.