Examples Of A Corporate FCPA Action After A Related Individual Action
In the modern era of FCPA enforcement, most DOJ FCPA enforcement actions against business organizations do not involve related criminal charges against individuals associated with the organization. (See here).
When individuals associated with the company are also charged – based on the same core conduct alleged, in whole or in part, in the corporate action – the process generally occurs in one of three ways.
The corporate action and the individual action(s) occur on the same day.
The corporate action occurs first, followed (sometimes by months or longer) the individual action(s).
The individual action(s) occur first, followed (sometimes by months or even years) the corporate action.