Discussing this, it seems to me, has a “the police have a traffic ticket quota to meet” quality to it. In any event, notwithstanding the Technip and Veraz Networks enforcement actions this week, and notwithstanding the fact that twenty-two individual defendants were indicted in the Africa Sting case (an event which causes a spike in the “statistics”), FCPA enforcement has slowed down thus far this year compared to the past few. For possible reasons why see this recent post from Richard Cassin at the FCPA Blog.
To recap, so far this year, there has been the “Kyrgyzstan, Thailand, Tobacco, and Piranha Fishing” SEC enforcement action (see here), the Daimler “bribery, yet no bribery” DOJ/SEC enforcement action (see here), the Innospec “we can’t afford to pay the full amount” DOJ/SEC enforcement action (see here), the BAE “non-FCPA, FCPA like” DOJ enforcement action (see here), the “Africa Sting” DOJ indictments (see here), and the NATCO “extortion can still lead to FCPA books and records and internal control issues” SEC enforcement action (see here).
With much pre-enforcement action news of late (see here among other posts), will July be the month in which the FCPA fireworks fly?
Last July saw many FCPA fireworks as the following enforcement actions were announced: Control Components Inc. (see here), Nature’s Sunshine Products, Inc. (see here), Helmerich & Payne Inc. (see here), and Avery Dennison (see here).
While waiting for the figurative fireworks, enjoy the real stuff.
Until next week, a Happy Fourth of July weekend to all! To my non-U.S. readers, a swell few days to you as well!