This recent post highlighted the $6.3 million Foreign Corrupt Practices Act enforcement action against KT Corp. – a South Korea based telecommunications company with American Depositary Shares registered with the SEC and traded on the New York Stock Exchange.
This post highlights additional issues to consider.
Proper?
In the FCPA’s modern era, much of the largeness of enforcement activity is from enforcement actions against foreign companies from peer OECD Convention countries.
The first corporate FCPA enforcement action of 2022 is another example.