Year in Review 2018 Archives - Page 2 of 4

A Focus On DOJ Individual Actions

By Mike Koehler on January 16, 2019 in DOJ, FCPA Statistics, Individual Enforcement Action, Year in Review 2018

This recent post focused on SEC individual FCPA actions in 2018 and historically and this post highlights certain facts and figures concerning the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act violations in 2018 and historically.

As highlighted numerous times on FCPA Professor over the past several years, the DOJ frequently talks about the importance of individual criminal prosecutions.

In 2018, DOJ officials stated: “focusing on individual wrongdoers is an important aspect of the Department’s FCPA program” and as follows:

A Focus On SEC Individual Actions

By Mike Koehler on January 15, 2019 in FCPA Statistics, Individual Enforcement Action, SEC, Year in Review 2018

This previous post highlighted various facts and figures from 2018 SEC FCPA enforcement actions against issuers.

As highlighted in the prior post, of the 14 corporate SEC FCPA enforcement actions in 2018, 1 (7%) has involved, at present, related SEC FCPA charges or findings against company employees.

In 2018, the SEC charged or found that three individuals violated the FCPA: Joo Hyun Bahn (associated with Colliers International Group); Patricio Contesse Gonazlez (associated with SQM which resolved an FCPA enforcement action in 2017); and Paul Margis (associated with Panasonic Avionics). (Note: the SEC’s enforcement action against Takeshi Uonaga (Panasonic Avionics former CFO) is not included in FCPA enforcement statistics for the simple reason that this was a revenue recognition matter and thus a non-FCPA FCPA enforcement action).

The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2018

By Mike Koehler on January 10, 2019 in FCPA Statistics, Gray Cloud, Year in Review 2018

This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2018.

Continuing with the 2018 FCPA statistical feast, this post follows the chronology of scrutiny to 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 approximate median length of time companies that resolved FCPA enforcement actions in 2018 were under scrutiny.

SEC FCPA Enforcement – 2018 Year In Review

By Mike Koehler on January 8, 2019 in Disgorgement, FCPA Statistics, SEC, SEC Enforcement Action, Year in Review 2018

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 highlighted various corporate enforcement statistics from 2018, this post focused more specifically on DOJ enforcement in 2018, and this post goes in-depth into various facts and figures relevant to SEC FCPA enforcement in 2018.

DOJ FCPA Enforcement – 2018 Year In Review

By Mike Koehler on January 7, 2019 in DOJ, DOJ Enforcement Action, FCPA Statistics, Monitor, Voluntary Disclosure, Year in Review 2018

This previous post highlighted various corporate Foreign Corrupt Practices Act enforcement statistics from 2018 and this post goes in-depth into various facts and figures relevant to DOJ FCPA enforcement in 2018. (See here for a similar post from 2017, here for a similar post from 2016, 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 2018, the DOJ brought 8 corporate FCPA enforcement actions.

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A Focus On DOJ Individual Actions

A Focus On SEC Individual Actions

The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2018

SEC FCPA Enforcement – 2018 Year In Review

DOJ FCPA Enforcement – 2018 Year In Review

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