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Reading Assignment For All Executive Officers: The Mace Enforcement Action

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The recent Foreign Corrupt Practices Act enforcement action against Anthony Mace (the former CEO of SBM Offshore) is a must read

FCPA lawyers should send this post to their clients. In-house counsel and other compliance professionals should send this post to their executive officers and the Mace enforcement action should make its way into FCPA training and communications.

For starters, criminal FCPA enforcement actions against large company employees are unusual. (As highlighted in this prior post, the vast majority of individual criminal FCPA enforcement actions are against persons associated with small, privately held business organizations).

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DOJ Announces FCPA Enforcement Action Against Two Former SBM Offshore Executives

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If you are scoring at home, in the past 48 hours the DOJ has announced FCPA enforcement actions involving 7 individuals. (See here for the prior post regarding the FCPA enforcement action earlier this week against 5 individuals associated with Rolls-Royce).

By way of comparison, as highlighted in this post, in all of 2016 8 individuals were involved in DOJ FCPA enforcement actions and in 2015 8 individuals were also involved in DOJ FCPA enforcement actions.

In other words, those predicting a slow down in FCPA enforcement in the Trump administration were ignorant to begin with, but now really need to move on to other topics.

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