September is a great month. The heat and humidity of July and August have largely subsided, evenings are crisp and cool, the leaves begin to change, college football returns to campus, and oh those honeycrisp apples!
As highlighted in this post, historically September has tended to be an active month for FCPA enforcement. Most notably, the SEC’s fiscal year ends on September 30th and while we would like to think that the government does not “close its books” like a business organization at the end of a fiscal year, this most certainly appears to be the case.
As further highlighted, September has also tended to be an active month for enforcement agency speeches as “official Washington” gets back to its business of making rhetoric filled policy speeches.