Yesterday’s post compared corporate FCPA enforcement actions in 2017 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 2017 corporate enforcement actions. (See here for a similar post highlighting the origins of 2016 corporate enforcement actions).
As highlighted in the post, like prior years, 2017 corporate enforcement actions originated in a variety of ways from voluntary disclosures, to foreign media reporting and foreign law enforcement investigations, to pro-active SEC investigations, to civil litigation.