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Paul J. McNulty
Baker & McKenzie LLP

Mr. McNulty joined Baker & McKenzie as a partner in the firm’s Washington, DC office in 2007 after a long career of public service. He plays a key leadership role in the Firm's Business Crimes and Investigations and Corporate Compliance and Risk Management practices and to the firm’s global team. From 2005 to 2007, he served as US Deputy Attorney General, the second highest-ranking official in the Department of Justice and chief operating officer of its more than 100,000 employees. Mr. McNulty is the author of the controlling statement on federal prosecution of business organizations – the "McNulty Memorandum" – an essential element in determining how a corporation should respond to allegations of criminal wrongdoing.
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Fraud, Bribery & Corruption: What Will Happen in 2010?

by Paul J. McNulty, Dec 31, 2009

My anti-corruption enforcement prediction for 2010 is that the Department of Justice will undergo a major leadership transition within the section responsible for FCPA enforcement. Therefore, while the four-year surge in enforcement will continue for at least the next few years, we’ll be well into the summer before the decision-makers are settled in and up to speed, which may slow down progress on “big cases.” Also, we expect to see the Department follow-through on their warning to go after pharmaceutical and other life sciences companies for corrupt marketing practices.

And my New Year’s tip? Get ready for tough questions from the government on third-party due diligence. The government now expects companies to exercise greater control of their overseas business partners (e.g., agents, consultants, distributors, brokers). Consequently, compliance systems need to be as robust as possible.

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