This previous post highlighted the recent net $443 million Foreign Corrupt Practices Act enforcement action against Glencore.
This post highlighted the CFTC’s related enforcement action against the company.
This post discussed how the executive officer certification in the FCPA enforcement action sets up Glencore personnel to fail.
This post continues the analysis by highlighting additional issues to consider from the Glencore FCPA enforcement action.
Timeline
This previous post highlighted the recent net $59 million Foreign Corrupt Practices Act enforcement action against Stericycle (an Illinois based medical waste disposal company) for conduct in Brazil, Mexico, and Argentina.
Portions of the alleged conduct were egregious in that an executive of the company’s Latin America division orchestrated the bribery schemes and others associated with the company used “spreadsheets to track the bribe payments.”
Nevertheless, there are several legal and policy issues to consider from the enforcement action.
Timeline
As highlighted in this post, Stericycle disclosed its FCPA scrutiny in mid-2017.
