Checking In On Non-FCPA, FCPA Enforcement Actions
There was not an acceleration of Foreign Corrupt Practices Act enforcement actions in the final weeks of the Biden administration similar to what happened in the final weeks of the Obama administration (see here).
There were however several non-FCPA, FCPA enforcement actions brought by the SEC.
What is a non-FCPA, FCPA enforcement action?
It is a term long used on this site to describe enforcement actions charging or finding violations of the FCPA’s books and records and internal controls provisions, but not in the context of foreign bribery.
This post highlights five recent actions.