Lessons for compliance practitioners in the tech sector – Garcia FCPA enforcement action

Last month, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) jointly announced an enforcement action for violations of the Foreign Corrupt Practices Act (FCPA) against a former executive of the SAP International Inc. for bribery and corruption to procure government contracts in Panama. Even at this point, with no DOJ or SEC action against SAP, there are several lessons for compliance practitioners.


How Canada’s leading the way to compliance with anti-corruption sticks and carrots

I was debarred from being a U.S. government contractor, and based on my conduct and offense, it was an appropriate and fair decision. The process by which I was suspended and ultimately debarred was also fair and appropriate. While the debarment tactic is rarely enforced, Canada’s leading the way to compliance by offering rehabilitation.