Nine companies disclose new FCPA investigations
So far in 2021, nine companies have disclosed new FCPA investigations. All nine new FCPA investigations disclosed by issuers remain active and open, according to the companies.… Continue Reading
So far in 2021, nine companies have disclosed new FCPA investigations. All nine new FCPA investigations disclosed by issuers remain active and open, according to the companies.… Continue Reading
As a government outsider, it’s impossible to know why there hasn’t yet been any DOJ or SEC corporate enforcement of the FCPA under the current administration. Here are three possible reasons:… Continue Reading
How much has FCPA enforcement and compliance changed over the last decade? Ask anyone who’s been around, and they’ll probably say “a lot” or “completely.” Perhaps the most telling metric quantifying this change is the average size of a corporate FCPA resolution.… Continue Reading
In 2020, the DOJ and SEC brought FCPA enforcement actions against 12 companies and imposed financial penalties totaling a record $6.4 billion. For a comparison, in 2019, 14 companies paid a (then) record $2.9 billion to resolve FCPA cases.… Continue Reading
Non-U.S. companies have long dominated the FCPA Blog Top Ten list, and currently occupy nine of ten places. That means the DOJ and SEC (no matter who’s in the White House) apply the FCPA unfairly, using it to “punish” mainly big, well-known foreign businesses, right?… Continue Reading
During the third calendar quarter, there were three corporate FCPA enforcement actions with penalties and disgorgement totaling about $182.7 million.… Continue Reading
This is the second post in a series on the theories of criminal punishment on which modern anti-bribery enforcement is based. Part One is here.
Deterrence. It’s been called the holy grail of criminal punishment.… Continue Reading