In 2013, twelve companies paid $731.1 million to resolve FCPA cases (that includes IBM’s $10 million settlement from 2011 that received final court approval in 2013). Two of the twelve corporate actions — Total SA and Weatherford — landed in the top ten FCPA cases of all time.… Continue Reading
There were four FCPA corporate enforcement actions during the first quarter of the year (we lump parent and subsidiary companies together). That’s a normal amount of activity. In both 2011 and 2010, there were also four corporate actions during the same period.… Continue Reading
During the calendar quarter just ended, there were three corporate enforcement actions and two individual convictions. A defendant received one of the FCPA’s longest jail sentences, the DOJ released three new FCPA-related indictments, and prosecutors dropped the appeal of a short FCPA prison term.… Continue Reading
A few years ago, after a dozen or so enterprising law students asked me what FCPA-related topics were ripe for research, I answered with a post on the FCPA Blog.
My suggestions included: (1) respondeat superior—the legal doctrine imputing to corporate employers the criminal acts of employees; (2) the sad state of the Department of Justice’s Opinion Procedure Releases; and (3) the confusing condition of the FCPA’s promotional-expenses affirmative defense.… Continue Reading
Lists are fun and can be helpful. Here are some about FCPA enforcement that might come in handy:
Let us know if there are other FCPA-related lists you’d like to see.… Continue Reading