This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2020.
Continuing with the 2020 FCPA statistical feast, this post follows the chronology of scrutiny to enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.
That is – FCPA scrutiny simply lasts too long. Specifically, as highlighted below, 4 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2020 were under scrutiny.
Before highlighting the statistics, some general background.