Key Tronic And Executives Resolve Non-FCPA, FCPA Enforcement Action
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions) have nothing to do with foreign bribery. For lack of a better term, these enforcement actions have longed been called non-FCPA, FCPA enforcement actions by this site.
The latest example concerns an SEC enforcement action against Key Tronic (a contract manufacturer of products such as computer components and medical devices), Brett Larsen (Key Tronic’s CFO from July 2015 to June 2024, and is now the company’s CEO) and Nicholas Fasciana (Key Tronic’s Senior Vice President of U.S. Operations).