This post highlighted the recent net $38.1 million Foreign Corrupt Practices Act enforcement action against Gol Linhas Aereas Inteligentes S.A. (Gol) – an airline headquartered in Sao Paulo, Brazil with shares traded on the New York Stock Exchange – for bribing Brazilian officials.
This post highlights additional issues to consider from the enforcement action.
Timeline
As highlighted in this prior post, Go’s FCPA (and related) scrutiny began in late 2016.
Thus from start to finish, Gol’s FCPA scrutiny lasted an approximate six years.
