FCPA Professor will once again be the place to visit in January for a plethora of 2019 year in review statistics.
But first, this post closes out the fourth quarter of 2019. (See here for a similar post for the first quarter of 2019, here for the second quarter of 2019, and here for the third quarter of 2019).
DOJ Enforcement (Corporate)
The DOJ brought 2 corporate FCPA enforcement action in the fourth quarter. Recovery in these enforcement actions was approximately $558 million.
This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the third quarter of 2019. (See here for a similar post for Q1 2019 and here for Q2 2019).
DOJ Enforcement (Corporate)
The DOJ brought one corporate FCPA enforcement action in the third quarter. DOJ recovery in this action was $8.8 million.
Scrutiny alert, the irony of it all, just saying …, not sure why, no more third parties, and for the reading stack. It’s all here in the Friday roundup.
Scrutiny Alerts
AAR Corp.
The company, a provider of aviation services with numerous U.S. government contracts, recently disclosed:
“The Company retained outside counsel to investigate possible violations of the Company’s Code of Conduct, the U.S. Foreign Corrupt Practices Act, and other applicable laws, relating to the Company’s activities in Nepal and South Africa. Based on these investigations, we self-reported these matters to the U.S. Department of Justice, the U.S. Securities and Exchange Commission and the UK Serious Fraud Office. The Company will fully cooperate in any review by these agencies, although we are unable at this time to predict what action, if any, they may take.”
This post highlights Foreign Corrupt Practices Act enforcement and related developments at the mid-point of 2019. As highlighted below, 2019 FCPA enforcement is already the third-most active year in FCPA history as measured by the amount of net settlements (approximately $1.5 billion) secured by the U.S. government.
For a similar post at the mid-point of 2018 see here, for 2017 see here, and for 2016 see here.
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 2019.
This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the second quarter of 2019. (See here for a similar post for Q1 2019).
DOJ Enforcement (Corporate)
The DOJ brought two corporate FCPA enforcement actions in the second quarter. DOJ recovery in these actions was approximately net $219 million.
