Like Prior Years, The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2023
This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2023.
Continuing with the 2023 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, 5 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2023 were under scrutiny.
Issues To Consider From The Tysers And H.W. Wood Enforcement Actions
This previous post discussed the related DOJ Foreign Corrupt Practices Act enforcement actions against United Kingdom reinsurance brokers Tysers Insurance Brokers Limited (acquired by AUB Group in 2022) and H.W. Wood Limited for “participation in a corrupt scheme to pay bribes to Ecuadorian government officials.”
This post highlights additional issues to consider.
Timeline
AUB previously disclosed in 2022.
Issues To Consider From The Lifecore Enforcement Action
This previous post concerned the FCPA enforcement action against Lifecore Biomedical, Inc. (f/k/a Landec Corporation) in connection with alleged Foreign Corrupt Practices Act violations involving wastewater issues in Mexico.
This post highlights additional issues to consider.
Timeline
As highlighted in this prior post, in January 2020 Landec disclosed:
Issues To Consider From The Albemarle Enforcement Action
This recent post highlighted the net $218.4 million enforcement action against chemical company Albemarle Corp.
This post highlights additional issues to consider from the enforcement action.
Timeline
As highlighted in this prior post, in February 2018 Albemarle Corp. disclosed scrutiny. Specifically, the company disclosed:
Issues To Consider From The Clear Channel Outdoors Enforcement Action
This recent post highlighted the $26.1 million enforcement action against Clear Channel Outdoors based on the conduct of a former indirect, majority-owned Chinese subsidiary (Clear Media Limited).
This post highlights additional issues to consider from the enforcement action.
Timeline
As highlighted here, in April 2018 disclosed FCPA scrutiny.
Thus, from start to finish, Clear Channel’s FCPA scrutiny lasted an unconscionable 5.5 years.