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Further To The Clustering Phenomenon, DOJ Announces Additional Guilty Pleas In Connection With PDVSA Bribery Scheme

cluster

Few corporate Foreign Corrupt Practices Act enforcement actions involve related criminal charges against company employees.

Perhaps sensitive to its individual FCPA prosecution numbers, the DOJ sure seems to cluster enforcement around a few discreet instances of bribery almost always involving private business entities.

This dynamic was first highlighted in this 2014 post and further discussed in this 2016 statistical post.

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