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What You Need To Know From Q4

Q4

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the fourth quarter of 2017. (See here for a similar post for the first quarter of 2017, here for the second quarter of 2017, and here for the third quarter of 2017).

DOJ Enforcement (Corporate)

The DOJ brought 2 corporate FCPA enforcement actions in the fourth quarter. DOJ recovery in these enforcement actions was $343.5 million (after accounting for various credits and deductions for contemplated related foreign law enforcement actions). Both of these actions also included related DOJ individual FCPA enforcement actions.

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What You Need To Know From Q3

q3

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the third quarter of 2017. (See here for a similar post for the first quarter of 2017 and here for the second quarter of 2017).

DOJ Enforcement (Corporate)

The DOJ brought one corporate FCPA enforcement action in the third quarter. DOJ recovery in this enforcement action was approximately $275 million (after accounting for various credits and deductions for contemplated related foreign law enforcement actions). This action has not resulted (at least yet) in any related DOJ individual FCPA enforcement actions.

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Friday Roundup

Roundup

Guilty plea, scrutiny alerts, and for the reading stack. It’s all here in the Friday roundup.

Guilty Plea

As highlighted in this prior post, in July 2011 the DOJ criminally charged Amadeus Richers (a former director of Cinergy Telecommunications with one count of conspiracy to violate the FCPA and to commit wire fraud, six counts of FCPA violations, one count of conspiracy to commit money laundering and 19 counts of money laundering) in the sprawling Haiti Teleco enforcement action.

Although Richers was indicted, he remained a fugitive until his arrest and ultimately his extradition from Panama on February 23, 2017.

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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 2017. For a similar post at the mid-point of 2016 see this prior post.

This post breaks down FCPA enforcement into the following categories: DOJ (corporate); DOJ (individual); SEC (corporate); and SEC (individual). Thereafter, this post highlights other FCPA developments or items of interest thus far in 2017.

DOJ Enforcement (Corporate)

The DOJ has brought 6 corporate FCPA enforcement actions in 2017. DOJ recovery in these actions has been approximately $225 million. The Rolls Royce enforcement action ($170 million) accounts for 75% of the DOJ’s recovery.

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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 2017. (See here for a similar post for the first quarter of 2017).

DOJ Enforcement (Corporate)

The DOJ brought 2 corporate FCPA enforcement actions in the second quarter. DOJ recovery in these actions was approximately $15 million. None of these enforcement actions have resulted (at least yet) in any related DOJ individual FCPA enforcement actions.

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