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A Focus On SEC Individual Actions

SEC

After a wild week or so in 2017 Foreign Corrupt Practices Act enforcement, back to some 2016 FCPA enforcement statistics.

This previous post highlighted various facts and figures from 2016 SEC FCPA enforcement actions against issuers.

As highlighted in the prior post, of the 24 corporate SEC FCPA enforcement actions from 2016, 7 (29%) have involved, at present, related SEC charges or findings against company employees.

In 2016, the SEC charged or found that 8 individuals violated the FCPA.

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Corporate FCPA Enforcement In 2016 Compared To Prior Years

Statistical Analysis

Previous posts this week (here and here) separately analyzed DOJ and SEC corporate Foreign Corrupt Practices Act enforcement in 2016.

Viewing FCPA enforcement statistics this way is useful and informative given that the DOJ and SEC are separate law enforcement agencies and different issues may arise in DOJ and SEC FCPA enforcement actions.

By way of review, below are the 2016 DOJ and SEC FCPA enforcement statistics compared to prior years.

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SEC Enforcement Of The FCPA – 2016 Year In Review

SEC

Foreign Corrupt Practices Act enforcement, it’s not just about the DOJ.

Granted, as a civil enforcement agency the SEC’s sticks are less sharp than the DOJ’s, but the SEC also claims a significant piece of the FCPA enforcement pie (query whether it should – but that is a subject for another day – for instance as discussed in “The Story of the Foreign Corrupt Practices Act” the SEC wanted no part in enforcing the FCPA’s anti-bribery provisions).

This previous post was a 2016 year in review of DOJ FCPA enforcement.

Today’s post is a 2016 year in review of SEC FCPA Enforcement.  (See here for a similar post for 2015; here for a similar post for 2014; here for a similar post for 2013; here for a similar post for 2012; here for a similar post for 2011; and here for a similar post for 2010).

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DOJ Enforcement Of The FCPA – 2016 Year In Review

DOJ2

This post highlights facts and figures from corporate Foreign Corrupt Practices Act enforcement actions in 2016 by the DOJ. (See here for a similar post from 2015, here for a similar post from 2014, here for a similar post from 2013, here for a similar post from 2012, here for a similar post from 2011, and here from 2010).

Settlement Amounts and Specifics

In 2016, the DOJ brought 13 corporate FCPA enforcement actions (the second-largest number of all-time behind 2010 in which the DOJ brought 17 corporate FCPA enforcement actions).

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The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2016

Gray Cloud

This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2016.

Continuing with the FCPA statistical feast, this post follows the chronology of FCPA scrutiny to FCPA enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.

That is – FCPA scrutiny simply lasts too long. Specifically, as highlighted below, 4.25 years was the median length of time companies that resolved FCPA enforcement actions in 2016 were under scrutiny.

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