- FCPA Professor - https://fcpaprofessor.com -

July Fireworks?

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 [1] 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 [2]), the Daimler “bribery, yet no bribery” DOJ/SEC enforcement action (see here [3]), the Innospec “we can’t afford to pay the full amount” DOJ/SEC enforcement action (see here [4]), the BAE “non-FCPA, FCPA like” DOJ enforcement action (see here [5]), the “Africa Sting” DOJ indictments (see here [6]), and the NATCO “extortion can still lead to FCPA books and records and internal control issues” SEC enforcement action (see here [7]).

With much pre-enforcement action news of late (see here [8] 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 [9]), Nature’s Sunshine Products, Inc. (see here [10]), Helmerich & Payne Inc. (see here [11]), and Avery Dennison (see here [12]).

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!