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A Focus On DOJ Individual Actions

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This recent post focused on SEC individual FCPA actions in 2019 and historically. Today’s post highlights certain facts and figures concerning the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act violations in 2019 and historically.

The key word above is FCPA violations.

Some in the FCPA space include enforcement actions containing non-FCPA charges (often money laundering charges against alleged “foreign officials”) related to an FCPA enforcement action as an individual FCPA enforcement action. While it is fine to track such enforcement actions, calling them FCPA enforcement actions is factually false.

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