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.
Prioritize the Message, Not the Messenger: RUSI’s Eliza Lockhart on Why Whistleblower Rewards Work
At a side event during the UN crime convention’s 13th Conference of the Parties, RUSI researcher Eliza Lockhart walked delegates through how whistleblower reward programs work, what her research found…
