This previous post went in-depth regarding the $22 million parallel DOJ and SEC enforcement action against LAN Airlines.
This post continues the analysis of the enforcement action by highlighting additional issues to consider.
As noted in connection with the prior SEC enforcement action against Ignacio Cueto Plaza, the conduct at issue is notable for several reasons.
First, the problematic conduct was engaged in by an individual currently with the company. The vast majority of FCPA enforcement actions involve the conduct of former employees.