Issues To Consider From The Boston Consulting Group Enforcement Action
This previous post highlighted the recent $14.4 million Foreign Corrupt Practices Act enforcement actions against Boston Consulting Group (BCG) concerning conduct in Angola.
This post highlights additional issues to consider.
Voluntary Disclosure
The DOJ’s “declination with disgorgement” letter mentions “BCG’s timely and voluntary self-disclosure of the misconduct, which occurred after BCG uncovered evidence, in the form of a 2014 email, of a potential FCPA violation.”
Boston Consulting Group Disgorges $14.4 Million In FCPA Matter
So-called “declinations with disgorgement” (first used by the DOJ in a Foreign Corrupt Practices Act in 2016) are just another resolution vehicle – among others – used by the DOJ to resolve alleged instances of FCPA scrutiny.
The latest example concerns Boston Consulting Group.
An August 27th letter from the DOJ to the company’s counsel (Cadwalader attorneys Jason Halper and Gina Catellano) and posted to the DOJ’s Corporate Enforcement Policy Declination Page on August 28th states in full: