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.