Roundup Of Recent Non-FCPA, FCPA Enforcement Actions
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions) have nothing to do with foreign bribery. For lack of a better term, these enforcement actions have longed been called non-FCPA, FCPA enforcement actions by this site.
By my count, in the last approximate 30 days (as the SEC’s fiscal year came to a close), the SEC announced eight such actions. (See here, here, here, here and here for previous posts).
This post rounds up the other non-FCPA, FCPA enforcement actions in recent days.