This prior post went in-depth into the recent Microsoft Foreign Corrupt Practices Act enforcement action and this post continues the analysis by highlighting additional issues to consider.
Timeline
As highlighted in this prior post, Microsoft was reportedly under FCPA scrutiny in various countries since early 2013. Thus, from start to finish the various facets of the company’s FCPA scrutiny lasted an unconscionable 6.5 years. If the DOJ and SEC want their FCPA enforcement programs to be viewed as credible and effective, they must resolve instances of FCPA scrutiny much quicker.