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Issues To Consider From The Juniper Networks Enforcement Action

Issues

This prior post highlighted the SEC’s $11.7 million Foreign Corrupt Practices Act enforcement action against Juniper Networks. This post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this prior post, Juniper Networks disclosed its FCPA scrutiny in mid-2013. Thus, from start to finish the company’s FCPA scrutiny lasted an unconscionable six years.

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Issues To Consider From The Deutsche Bank Enforcement Action

Issues

This prior post highlighted the SEC’s $16.2 million Foreign Corrupt Practices Act enforcement action against Deutsche Bank – the latest FCPA enforcement action focused on alleged improper internship and hiring practices primarily involving the financial services industry.

This post continues the analysis by highlighting additional issues to consider.

Timeline

The company’s FCPA scrutiny reportedly began in mid-2013. Thus, from start to finish, Deutsche Bank’s FCPA scrutiny lasted an unconscionable six years.

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Issues To Consider From The Microsoft Enforcement Action

Issues

This prior post went in-depth into the recent Microsoft Foreign Corrupt Practices Act enforcement action and this post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this prior post, Microsoft was reportedly under FCPA scrutiny in various countries since early 2013. Thus, from start to finish the various facets of the company’s FCPA scrutiny lasted an unconscionable 6.5 years. If the DOJ and SEC want their FCPA enforcement programs to be viewed as credible and effective, they must resolve instances of FCPA scrutiny much quicker.

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The Top Ten List Of FCPA Disgorgement Amounts

top ten

Everybody, it seems, likes “Top Ten” lists.

This post highlights the top ten corporate FCPA disgorgement (and prejudgment interest) amounts in FCPA history.

The list highlights net FCPA disgorgement (and prejudgment interest) amounts after consistently accounting for (unlike other lists out there) certain credits or deductions in enforcement actions for foreign law enforcement actions or forfeiture amounts paid to the DOJ in a parallel proceeding.

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Issues To Consider From The Fresenius Enforcement Action

Issues

This previous post went in-depth into the approximate $232 million Fresenius FCPA enforcement action and this post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this prior post, Fresenius disclosed its FCPA scrutiny in August 2012. Thus from start to finish, its FCPA scrutiny lasted an unconscionable 6.5 years.

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