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Like Prior Years, The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2021

Gray Cloud

This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2021.

Continuing with the 2021 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 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2021 were under scrutiny.

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The Origins Of 2021 Corporate Enforcement Actions

start

This recent post compared corporate FCPA enforcement actions in 2021 to prior years. However, before a Foreign Corrupt Practices Act enforcement action is announced, scrutiny must first arise.

This post highlights the origins of the four core corporate enforcement actions in 2021. (See here for a similar post highlighting the origins of 2020 corporate enforcement actions; here for 2019, here for 2018, here for 2017, and here for 2016).

Compared to prior years, this year in review statistic (like many from 2021) is less than enlightening given the small number of corporate enforcement actions in 2021 coupled with the fact that the specific origin of an enforcement action is often dependent on information contained in a resolution document.

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Corporate FCPA Enforcement In 2021 Compared To Prior Years

Statistical Analysis

This post, the first in a weeks-long statistical feast on FCPA Professor, compares corporate FCPA enforcement in 2021 to prior years.

Keep the numbers in this post in mind when you see other 2021 FCPA enforcement statistics that are plainly false (see here) or that use creative and haphazard counting methods or fail to use accurate or consistent math (see here).

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What You Need To Know From Q4

Q4

FCPA Professor will once again be the place to visit in January for a plethora of 2021 year in review statistics. But first, this post closes out the fourth quarter of 2021. (See here for Q1, here for Q2 and here for Q3).

DOJ Enforcement (Corporate)

The DOJ did not bring any corporate FCPA enforcement action in the fourth quarter.

DOJ Enforcement (Individual)

The DOJ announced an enforcement action against one individual in the fourth quarter.

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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 2021. (See here for Q1 and here for Q2).

DOJ Enforcement (Corporate)

The DOJ did not bring any corporate FCPA enforcement action in the third quarter.

DOJ Enforcement (Individual)

The DOJ announced three individual FCPA enforcement actions in the third quarter.

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