Individual Enforcement Action Archives

Slumbering Individual FCPA Enforcement Actions

By Mike Koehler on September 20, 2023 in Individual Enforcement Action, Uncategorized

Most in the Foreign Corrupt Practices Act space learn when the DOJ announces criminal FCPA charges against individuals. Thereafter, the tendency (including by myself) is to sort of forget about many of the individual cases.

However, recently I examined the dockets for all individuals criminally charged with FCPA offenses since January 1, 2017 and was surprised to learn that a meaningful percentage of these cases are slumbering with no substantive activity recorded in quite some time.

Thus, when viewing DOJ FCPA individual enforcement action statistics it is important to keep in mind that many of these cases are slumbering and are not being actively prosecuted.

The Gap In SEC Individual FCPA Enforcement Actions Is Approaching Three Years

By Mike Koehler on July 18, 2023 in Individual Enforcement Action, SEC

One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted.

For instance, the FCPA enforcement agencies often talk about the importance of x and how they are committed to x, but in reality rarely do x.

Case in point is SEC individual FCPA enforcement actions.

For many years, SEC enforcement officials have talked about the importance of individual FCPA enforcement actions and set forth below are representative quotes from over the years.

Slumbering Individual FCPA Enforcement Actions

By Mike Koehler on April 17, 2023 in DOJ, Individual Enforcement Action

Thus, when viewing DOJ FCPA individual enforcement action statistics it is important to keep in mind that many of these cases are slumbering and are not being actively prosecuted.

Bankman-Fried Charged With FCPA Offense

By Mike Koehler on March 28, 2023 in 2023 Enforcement Action, Alameda, China, Cryptocurrencies, DOJ Enforcement Action, FTX, Individual Enforcement Action, Samuel Bankman-Fried

In December 2022, the Department of Justice announced criminal charges against Samuel Bankman-Fried arising from an “alleged wide-ranging scheme by [him] to misappropriate billions of dollars of customer funds deposited with FTX, the international cryptocurrency exchange [he] founded …, and mislead investors and lenders to FTX and to Alameda Research, the cryptocurrency hedge fund [he] also founded.”

Specifically, Bankman-Friend was charged with conspiracy to commit wire fraud, wire fraud, conspiracy to commit commodities fraud, conspiracy to commit securities fraud, conspiracy to commit money laundering, and conspiracy to defraud the Federal Election Commission and commit campaign finance violations.

Yesterday, the DOJ filed a superseding indictment adding a Foreign Corrupt Practices Act conspiracy charge to the criminal charges Bankman-Fried is facing.

The Gap In SEC Individual FCPA Enforcement Actions Is Now 2.5 Years

By Mike Koehler on March 23, 2023 in Individual Enforcement Action, SEC

One reason to take FCPA enforcement agency rhetoric with a grain of salt is because it is warranted.

For instance, the FCPA enforcement agencies often talk about the importance of x and how they are committed to x, but in reality rarely do x.

Case in point is SEC individual FCPA enforcement actions.

For many years, SEC enforcement officials have talked about the importance of individual FCPA enforcement actions and set forth below are representative quotes from over the years.

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Slumbering Individual FCPA Enforcement Actions

The Gap In SEC Individual FCPA Enforcement Actions Is Approaching Three Years

Slumbering Individual FCPA Enforcement Actions

Bankman-Fried Charged With FCPA Offense

The Gap In SEC Individual FCPA Enforcement Actions Is Now 2.5 Years

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