After this last week, I feel like my summer has finally come full circle. One of my first major projects at Dentons was drafting a note about anti-bribery/corruption statutes in the US, UK, and PRC. This past week, I was asked (yet again) to delve into the realm of anti-bribery/corruption. This time, I wrote a memo about the interplay of the FCPA with notions of agency and successor liability. Since the FCPA is over thirty years old now, one would expect to find a robust body of case law interpreting it. Sadly, the opposite is true. In fact, most of the major issues regarding agency and successor liability under the FCPA are only discussed in secondary sources. These discussions, while helpful in the abstract, lends little guidance to how a court is likely to rule.
In spite of all the frustrations, I still feel that the FCPA work I have done is the most interesting so far this summer.
Only two more weeks and I have to go back to the States. I'm already trying to plan for post-graduation. Specifically, I am planning a timeline to come back and work in China.