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Last month, Coinbase Inc., the operator of the largest U.S.-based cryptocurrency exchange platform, and Marden Kane, its promotions marketing agency, settled a class action lawsuit brought by participants of a Coinbase sweepstakes for $2.25 million. After nearly four years of litigation, including a trip to the U.S. Supreme Court over a conflict in dispute resolution clauses between the sweepstakes Official Rules and the Coinbase User Agreement, Coinbase and Marden-Kane agreed to settle.

Manatt Partners Randy Grossman and Kareem Salem and Associate Andrew Beshai wrote an article for Anti-Corruption Report discussing why it’s important for companies, especially in California, to continue their compliance with the Foreign Corrupt Practices Act (FCPA) despite the president’s executive order temporarily halting investigations and enforcement for violation of the act.

According to the article, after the president signed the executive order, the California Attorney General issued a legal alert as a reminder that the FCPA is still actionable as a violation of California’s Unfair Competition Law (UCL), which is a broad statute prohibiting “any unlawful, unfair or fraudulent business act or practice,” and in essence treats violations of other laws as unlawful. As seen in previous cases, a UCL claim can be premised on an FCPA violation, potentially leading to legal consequences and penalties. “As federal enforcement recedes, companies cannot afford to relax anti-bribery vigilance. California and potentially other states may assert their own authority using broad statutes like the UCL to fill the gap in anti-corruption enforcement resulting from shifting federal priorities,” the authors wrote.

Anti-Corruption Report subscribers can read the full article here.