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Mid-Year FCPA Report

mid-year report

This post highlights Foreign Corrupt Practices Act enforcement and related developments at the mid-point of 2016.

In doing so, this post contains several FCPA enforcement statistics. When publishing yearly FCPA enforcement statistics, I remind readers that any statistic with an arbitrary cutoff date is of marginal value. This reminder is even more important when interpreting mid-year 2016 FCPA statistics.

Another reminder, once again various FCPA Inc. participants are engaging in haphazard and creative counting methods that distort FCPA statistics. (See here for the article “A Common Language to Remedy Distorted FCPA Enforcement Statistics”).

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What You Need To Know From Q2

Q2

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the second quarter of 2016. (See here for a similar post for the first quarter of 2016).

DOJ Enforcement (Corporate)

The DOJ brought one corporate FCPA enforcement action in the second quarter. DOJ recovery in this action was approximately $3.4 million.

This enforcement action has not resulted (at least yet) in any related DOJ individual FCPA enforcement action.

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What You Need To Know From Q1

Q1

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2016.

DOJ Enforcement (Corporate)

The DOJ brought 3 corporate FCPA enforcement actions in the first quarter. DOJ recovery in these actions was approximately $267 million (after accounting for various credits and deductions in the VimpelCom action).

None of these enforcement actions have resulted (at least yet) in any related DOJ individual FCPA enforcement actions.

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Wow, That Was A Most Interesting 30-Day Period

wow

Over the past decade or so, I’ve been following Foreign Corrupt Practices Act enforcement as close as anybody. However, I do not recall a period as interesting as the past 30-day period (February 1 – March 3, OK that is slightly more than 30 days, but you get the point).

Two words come to mind, but because this is a professional website, I will simply say “wow”!

Wow not necessarily because there was 8 core enforcement actions. There have been 30-day periods before with a similar number of FCPA enforcement actions (for instance in November 2010 the DOJ/SEC announced on the same day related enforcement actions against 7 companies in the so-called CustomsGate enforcement action focused primarily on Nigeria customs issues).

Wow not necessarily because the recent FCPA enforcement actions netted approximately $472 million (with the Vimpelcom action comprising approximately 85% of this amount). Other 30-day periods have yielded higher settlement amounts (largely on the strength of just one or two enforcement actions).

Rather, wow because of the diversity of FCPA enforcement actions over the past 30 days.

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