Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Shruti J. Shah
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
As the year draws to a close, it’s time to recall the biggest stories from the FCPA Blog. Here are my choices for the top five stories we’ve covered during 2022, along with some personal favorites for honorable mention.… Continue Reading
The biggest FCPA resolutions yearly show enormous variation and no predictable pattern. Although four of the biggest cases for each of the past ten years settled for more than $1 billion, with an overall average settlement size for the ten cases of about $996 million, a couple of years were laggards.… Continue Reading
Following recent SEC filings that described previously unreported FCPA-related investigations, there are at least 100 confirmed ongoing investigations overall, with 20 new active investigations first disclosed since the start of 2020, according to data from FCPA Tracker.… Continue Reading
Compliance professionals have known for decades that intermediaries are involved in nearly all FCPA anti-bribery violations. The DOJ and SEC say plainly that FCPA enforcement actions “demonstrate that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions.”… Continue Reading
The FCPA Blog started publishing its list of the ten biggest FCPA corporate enforcement actions about a dozen years ago. Since then, I’ve written a lot about the top ten list, and I even did a series of talks, mainly in Asia, using the top ten list as a way to understand FCPA enforcement policy and attitudes toward compliance.… Continue Reading
When Switzerland-based Glencore paid the DOJ $700 million last week to settle widespread FCPA offenses, it earned a place on our FCPA top ten list, replacing a French bank and leaving Goldman Sachs as the only other bank currently on the list.… Continue Reading
I collect tidbits about FCPA enforcement. During good weeks, the tidbits come together for a post. Other times, they stubbornly remain random factoids. That’s what happened this week. No unified field theory of FCPA enforcement.… Continue Reading
They are so familiar to those of us who follow FCPA enforcement actions that we’re likely to stop noticing them. Petrobras in Brazil, Corpoelec and PDVSA in Venezuela, Pemex and CFE in Mexico, Takilant in Uzbekistan, Sonangol in Angola, Alba in Bahrain, Telecommunications D’Haiti, 1MDB in Malaysia, and Pertamina in Indonesia.… Continue Reading
What stands out on the FCPA Blog’s list of the ten biggest FCPA cases of all time?… Continue Reading
We’ve tabulated all countries reported in connection with the ten enforcement actions that comprise the latest FCPA Blog Top Ten list. Twenty-six different countries appear. Four of those countries are mentioned three times, and three appear twice.… Continue Reading
It’s a familiar FCPA enforcement pattern. Companies in the same segment fall like dominoes. Medical device makers, pharmas, banks, mobile phone operators, oil and gas service providers and producers — all have had their turn in the enforcement spotlight.… 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
