This previous post went in-depth into the $170 million Foreign Corrupt Practices Act enforcement action against U.K. based Rolls-Royce announced on January 17th. This post continues the analysis by highlighting additional issues to consider.
Unusual Aspect of the DPA
The Rolls-Royce DPA contains an unusual feature. Of the approximate $170 criminal penalty “$30 million will be paid to the Consumer Financial Fraud Fund.”
This has never happened before in an FCPA enforcement and set forth below is my e-mail exchange with the DOJ press office on this issue.