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The Origins Of 2017 Corporate FCPA Enforcement Actions

Yesterday’s post [1] 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 [2] 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.

Voluntary Disclosure (4)

Linde

CDM Smith

Halliburton

SBM Offshore

[3]

Foreign Media Reporting / Foreign Law Enforcement Investigations (4)

SQM

Rolls-Royce

Telia

Keppel Offshore & Marine

Prior FCPA Resolutions (2)

Zimmer Biomet

Orthofix

Pro-Active SEC Inquiries (2)

Mondelez

Alere

Civil Litigation (1)

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FCPA Institute - Seattle (August 13-14, 2018)

A unique two-day learning experience ideal for a diverse group of professionals seeking to elevate their FCPA knowledge and practical skills through active active. Learn more, spend less. CLE credit is available.

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