Well, that is a most curious headline isn’t it?
These pages have long highlighted SEC enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions – yet have nothing to do with foreign bribery.
For lack of a better term, these pages have long called such enforcement actions “non-FCPA, FCPA enforcement actions” and these enforcement actions have long been highlighted to emphasize the point that – because of the books and records and internal controls provisions – the FCPA has long been a law much broader than its name suggests.
Recently, both toy maker Mattel and cannabis company Cronos resolved enforcement actions implicating the books and records and internal controls provisions.
