Lucinda Low on FCPA Enforcement Trends Panel at Sixth Annual CLE Expo

Lucinda Low will be part of a panel, FCPA Enforcement Trends: Is Poor Recordkeeping Tantamount to a Bribe?, at MCCA's Sixth Annual CLE Expo held March 21-23, 2007, in Chicago, Illinois.

Panel members will discuss the steps to take to keep enforcers at bay, since recent enforcement actions related to the FCPA indicate that the traditionally narrow interpretations of key provisions are expanding. These key provisions include "anything of value" and "foreign officials." Benign neglect or poor recordkeeping by foreign subsidiaries abroad may trigger a subpoena at corporate headquarters.