Koehler on the FCPA

Mike Koehler (SIU) has posted Foreign Corrupt Practices Act Enforcement as Seen through Wal-Mart's Potential Exposure on SSRN with the following abstract:

High-profile instances of Foreign Corrupt Practices Act scrutiny focus attention on the law and its enforcement across a broad spectrum. In spring 2012, arguably the most high-profile instance of scrutiny in the FCPA’s 35-year history occurred as Wal-Mart’s alleged conduct in Mexico dominated the news cycle. Wal-Mart’s scrutiny has been instructive in many ways at a key point in time for the FCPA. This article uses Wal-Mart’s potential FCPA exposure as a prism to view the current FCPA enforcement environment.