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What Will September Bring?

September

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.

September 2016

Last September there were FCPA enforcement actions against the following companies.

GlaxoSmithKline (Sept. 30th)(SEC)

See here for the prior post

Och-Ziff (Sept. 29th)(DOJ & SEC)

See here and here for prior posts.

HMT LLC (Sept. 29)(DOJ)

See here for the prior post.

NCH Corp. (Sept. 29)(DOJ)

See here for the prior post.

AB InBev (Sept. 28th)(SEC)

See here for the prior post.

Nu Skin (Sept. 20th)(SEC)

See here and here for prior posts

September 2015

In September 2015, there were FCPA enforcement action against the following companies.

Hyperdynamics (Sept. 29th)(SEC)

See here for the prior post

Hitachi  (Sept. 28th)

See here and here for prior posts

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.

September 2016

As highlighted here, then SEC Chair Mary Jo White delivered a speech that focused on “a few priority areas that illustrate the dimensions of the SEC’s international role” and a substantial portion of the speech focused on the Foreign Corrupt Practices Act including how “vigorous enforcement of the FCPA is a high priority for both the SEC and DOJ.”

As highlighted here, then DOJ Principal Deputy Assistant Attorney General David Bitkower delivered a speech that focused on the FCPA including the DOJ’s so-called FCPA Pilot Program which he called “sophisticated” and “transparent.”

September 2015

As highlighted here, then DOJ Deputy Attorney General Sally Yates delivered a speech and released a DOJ policy memo memo titled “Individual Accountability for Corporate Wrongdoing.”

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Whatever happens this September, you can be sure that FCPA Professor will provide the most comprehensive and candid real-time coverage publicly available.

Thanks for reading.

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