In order for an individual defendant to be criminally liable under the FCPA, he or she must act “willfully.” The term “willfully” is not defined in the FCPA, but it has generally been construed by courts to connote an act committed voluntarily and purposefully, and with a bad purpose. The FCPA does not require the government to prove that a defendant was specifically aware of the FCPA or knew that their conduct violated the FCPA.
A New Era for UK Tax Enforcement: Inside HMRC’s “Breakthrough” Informant Reward Program
For decades, the global gold standard for fighting financial crime has been the U.S. whistleblower reward model—a system that incentivizes insiders to report high-value fraud in exchange for a percentage…
