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Friday Roundup


DOJ’s year in review, ripple, scrutiny alerts and updates, simply false, and amusing. It’s all here in the Friday roundup.

DOJ’s Year In Review

The DOJ Fraud Section recently released its year in review. According to the document, “the FCPA Unit has 32 prosecutors.” When reviewing the statistics in the document keep in mind that the FCPA Unit “investigates and prosecutes cases under the FCPA and related statutes.” In other words, the statistics include non-FCPA matters such as when the DOJ charges or prosecutes alleged “foreign officials” for money laundering and related offenses.

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Is This Appropriate?

© ClassicStock / Masterfile
Model Release: Yes
Property Release: No

Gibson Dunn is generally viewed as having a top tier Foreign Corrupt Practices Act practice.

The firm’s Year-End FCPA Update is always a quality read including this year’s version.

Yet, highlighted below is a paragraph from the Update that caught my eye and I ask: seriously – is this appropriate?

Early in the 36-page document is the following paragraph:

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An FCPA Statistical Feast

Kid in Candy Store

If the Foreign Corrupt Practices Act is an area of your practice or interest, this post may make you feel like a kid in a candy store.

With much rhetoric floating around regarding the FCPA and with many creative and haphazard counting methods employed by certain FCPA Inc. participants, it is instructive to take a look at actual statistics using accurate and consistently applied math.

FCPA Professor has been the place to visit this month for in-depth 2017 FCPA enforcement statistics as well as comparisons to historical statistics. If you missed the daily posts, no worries. This post consolidates in one place the statistics recently published on FCPA Professor.

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FCPA Enforcement Actions Against Foreign Companies From OECD Convention Peer Countries


As highlighted in this post, like prior years (see here) much of the largeness of 2017 FCPA enforcement resulted from corporate enforcement actions against foreign companies.

Specifically, of the 13 corporate enforcement actions from 2017, 5 (approximately 40%) were against foreign companies (based in many instances on mere listing of securities on U.S. markets and in a few instances on sparse allegations of a U.S. nexus in furtherance of an alleged bribery scheme). Even more dramatic, of the net $1.13 billion FCPA settlement amounts from 2017 corporate enforcement actions, approximately 90% of this number was from enforcement actions against foreign companies.

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The “Foreign Officials” Of 2017


A “foreign official.”

Without one, there can be no FCPA anti-bribery violation (civil or criminal).  Who were the alleged “foreign officials” of 2017?

This post highlights the alleged “foreign officials” from 2017 corporate DOJ and SEC FCPA enforcement actions.

There were 13 core corporate enforcement actions in 2017. Of the 13 enforcement actions 7 (54%) involved, in whole or in part, employees of alleged state-owned or state-controlled entities (“SOEs) with an additional 2 actions (15%) involving, in whole or in part, individuals associated with foreign health care systems.

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