Nowadays, it seems, things just can’t happen. Rather when things happen, it must be a sign of something else, causation is assumed, and a supposed new trend with big picture implications is unfolding.
For instance, this Fall there are four Foreign Corrupt Practices Act individual trials scheduled.
This is unusual.
But as highlighted below, it is likely a coincidence and not, as some commentators stated in this Law360 article, a sign that the DOJ’s FCPA Unit is “coming into its own” or that an “increase in prosecutors and agents is behind the uptick in cases.”