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The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2018

Gray Cloud

This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2018.

Continuing with the 2018 FCPA statistical feast, this post follows the chronology of scrutiny to enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.

That is – FCPA scrutiny simply lasts too long. Specifically, as highlighted below, 4.25 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2018 were under scrutiny.

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SEC FCPA Enforcement – 2018 Year In Review

SEC

Foreign Corrupt Practices Act enforcement, it’s not just about the DOJ.

Granted, as a civil enforcement agency the SEC’s sticks are less sharp than the DOJ’s, but the SEC also claims a significant piece of the FCPA enforcement pie (query whether it should – but that is a subject for another day – for instance as discussed in “The Story of the Foreign Corrupt Practices Act” the SEC wanted no part in enforcing the FCPA’s anti-bribery provisions).

This previous post highlighted various corporate enforcement statistics from 2018, this post focused more specifically on DOJ enforcement in 2018, and this post goes in-depth into various facts and figures relevant to SEC FCPA enforcement in 2018.

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DOJ FCPA Enforcement – 2018 Year In Review

Justice Dept

This previous post highlighted various corporate Foreign Corrupt Practices Act enforcement statistics from 2018 and this post goes in-depth into various facts and figures relevant to DOJ FCPA enforcement in 2018. (See here for a similar post from 2017, here for a similar post from 2016, here for a similar post from 2015, here for a similar post from 2014, here for a similar post from 2013, here for a similar post from 2012, here for a similar post from 2011, and here from 2010).

Settlement Amounts and Specifics

In 2018, the DOJ brought 8 corporate FCPA enforcement actions.

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The Origins Of 2018 Corporate FCPA Enforcement Actions

start

Yesterday’s post compared corporate FCPA enforcement actions in 2018 to prior years. However, before a Foreign Corrupt Practices Act enforcement action is announced, scrutiny must first arise.

Today’s post highlights the origins of 2018 corporate enforcement actions. (See here for a similar post highlighting the origins of 2017 corporate enforcement actions and here for 2016 corporate enforcement actions).

As highlighted in the post, like prior years, 2018 corporate enforcement actions originated in a variety of ways from voluntary disclosures, to pro-active government investigations and industry sweeps, to foreign law enforcement investigations.

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Corporate FCPA Enforcement In 2018 Compared To Prior Years

Statistical Analysis

This post, the first in a weeks-long statistical feast on FCPA Professor, compares corporate FCPA enforcement in 2018 to prior years. As reflected in this post, measured in terms of the number of core corporate actions, 2018 was the third most active year for enforcement in FCPA history.

Keep the numbers in this post in mind when you see other 2018 FCPA enforcement statistics (such as here and here) that use creative and haphazard counting methods or fail to use accurate or consistent math.

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