This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2017.
Continuing with the FCPA statistical feast, this post follows the chronology of FCPA scrutiny to FCPA 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, 4.5 years was the median length of time companies that resolved FCPA enforcement actions in 2017 were under scrutiny. (See here for the prior post highlighting that 4.25 years was the media length of time companies that resolved FCPA enforcement actions in 2016 were under scrutiny).