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Issues To Consider From The Philips Enforcement Action

Issues

This recent post highlighted the approximate $62 million Foreign Corrupt Practice Act enforcement action against Philips based on conduct in Angola. By resolving another FCPA enforcement action, Philips joined the corporate FCPA repeat offender club.

This post highlights additional issues to consider.

Timeline

As highlighted in this prior post, Philips had been under FCPA scrutiny since at least June 2019.

Thus, from start to finish, the company’s FCPA scrutiny lasted approximately four years.

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Across The Pond, Rolls-Royce Also Resolves A $625 Million U.K. Enforcement Action

Rolls

This recent post went in-depth into the $170 million Foreign Corrupt Practices Act enforcement action against Rolls-Royce. As mentioned in the post, the FCPA enforcement action against Rolls-Royce was part of a broader $800 million global resolution that also included a U.K. Serious Fraud Office component as well as Brazil law enforcement action.

The approximate $625 million U.K. enforcement action comprised the bulk of $800 million global resolution (that would seem to make sense, Rolls-Royce is after all a U.K. company) and is summarized below including the several failure to prevent bribery counts under the Bribery Act.

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Further To The Clustering Phenomenon, DOJ Announces Additional Guilty Pleas In Connection With PDVSA Bribery Scheme

cluster

Few corporate Foreign Corrupt Practices Act enforcement actions involve related criminal charges against company employees.

Perhaps sensitive to its individual FCPA prosecution numbers, the DOJ sure seems to cluster enforcement around a few discreet instances of bribery almost always involving private business entities.

This dynamic was first highlighted in this 2014 post and further discussed in this 2016 statistical post.

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