Lists are fun and can be helpful. Here are some about FCPA enforcement that might come in handy:
Top Ten FCPA Enforcement Actions
Enforcement Report for Q-1 ’11
The Corporate Investigations List
Let us know if there are other FCPA-related lists you’d like to see.
We’d like one showing which companies have received declinations — decisions by the government not to bring an enforcement action after a self-disclosure or an investigation. The DOJ doesn’t release that information now, which is too bad. It’s a missed opportunity for some important and perhaps encouraging transparency.
How about a list from SEC and DOJ enforcement actions that shows how offenders have concealed illicit payments, e.g. special fee, miscellaneous, etc.? That would be very interesting and helpful to FCPA audit programs.
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