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Better Late Than Never


The DOJ has a specific website devoted to the Foreign Corrupt Practices Act.

On the page you will find a purported chronological list and alphabetical list of enforcement actions (even though many of the enforcement actions do not actually involve FCPA charges – see here).

With any free website (let alone a government website), there is probably not an expectation that the website be updated every day or perhaps every week as developments occur.

However, is it asking too much for the DOJ to keep its FCPA website reasonably current – and thus accurate?

This question has occasionally being asked on this site for over a decade (see here for instance).

This prior post summarized the DOJ’s so-called Africa Sting FCPA enforcement action – a true debacle that the presiding federal judge called “a long and sad chapter in the annals of white collar criminal enforcement.”

The DOJ – rightly – shut down the enforcement action against 22 individual defendants in early 2012.

However, if your only source of information was the DOJ’s website – you would have never known – at least for a very long time.

However, as demonstrated by the below screen shot, the DOJ “updated” its original 2010 press release to reflect the final outcome. From the DOJ’s website this “update” appears to have been made in mid-2021 – nearly a decade later.

The Africa Sting enforcement action negatively impacted the lives of real people, damaged their real reputations, and drained their real pocketbooks.

Even though it happened long after it should have happened, it is nice to see that the DOJ finally provided an update to its manufactured enforcement action on its FCPA website.

The individuals deserved it.

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