With two weeks left in the semester and final exams thereafter, hypotheticals are dancing in my head.
But this question is no hypothetical.
In 2009, there were three FCPA trials - Frederic Bourke, William Jefferson, and Gerald and Patricia Green.
So here is the question.
What is the common thread in these three FCPA enforcement actions - a fact which speaks to the great difficulty individual FCPA defendants generally have in mounting a legal defense?
Please feel free to comment on this blog or otherwise send me your answer (perhaps there is more than one correct answer).
I am a quick grader, so stay tuned for the answer tomorrow.
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All were individuals that were prosecuted for FCPA violations, which is becoming a growing trend. All were found guilty of conspiracy to commit FCPA violations. And 2 (Jefferson and Green) were the result of undercover investigations, I'm not sure if Bourke was as well.
ReplyDeleteAnother common thread between the Greens and Jefferson is that the Greens were involved in the movie industry, and Jefferson's "cash in the freezer" plan may soon be mocked by the movie industry.