Previous posts here and here highlighted the late December 2018 Foreign Corrupt Practices Act enforcement actions against Eletrobras and Polycom. This post continues the analysis by highlighting additional issues to consider.
As highlighted in this previous post, in June 2015 it was reported that Eletrobras hired a law firm to investigate FCPA issues. Thus, the company’s FCPA scrutiny appears to have lasted approximately 3.5 years. Once again, if the SEC wants its FCPA enforcement program to be viewed as legitimate and credible, it must resolve instances of FCPA scrutiny much quicker.