This prior post highlighted the net $1.66 billion Foreign Corrupt Practices Act enforcement action against Goldman Sachs and a related entity.
This prior post posed the question, based on the government’s allegations, what should happen when compliance is decent (and often good), but not great? The prior post also highlighted how the Goldman enforcement action was much different than certain other top ten FCPA enforcement actions.
This prior post discussed various developments related to the Goldman FCPA enforcement action.
This post continues the analysis by highlighting additional issues to consider from the enforcement action.