This previous post highlighted the net $60.6 million Foreign Corrupt Practices Act enforcement action against Colombian entities Corficolombiana / Grupo Aval.
This post continues the analysis by highlighting additional issues to consider.
In the minds of some (including former FCPA enforcement officials), FCPA enforcement is a convenient cash cow for the U.S. government.
Those who believe this will find support in the Corficolombiana / Grupo Aval enforcement action.
The allegations were basically as follows.