If you were scoring at home, the last few weeks of the Obama administration were quite active for Foreign Corrupt Practices Act enforcement. But then again this was expected.
First it was the $13 million joke of an enforcement action against Mondelēz International, Inc. on January 9th. Then it was the $30.4 million Biomet became an FCPA repeat offender enforcement action on January 12th. Then it was no U.S. nexus, no problem $30.5 million enforcement action against Sociedad Quimica y Minera de Chile S.A on January 13th. Then it was the DOJ’s announcement (summarized in this post) on January 17th that U.K. based Rolls-Royce plc agreed to pay the U.S. net approximate $170 million (including an unusual component never before seen in FCPA enforcement) to resolve an FCPA enforcement action concerning conduct in Thailand, Brazil, Kazakhstan, Azerbaijan, Angola and Iraq. Then it was $6 million Orthofix Int’l also became an FCPA repeat offender enforcement action on January 18th. Then in the finals hours of the Obama administration it was unusual $7 million enforcement action against Las Vegas Sands (headed by major Republican donor Sheldon Adelson who was front and center at Trump’s inauguration) based on the same core conduct as the SEC’s enforcement action against the company nine months earlier. Individual FCPA enforcement actions (here and here) were sprinkled in as well.