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The Origins Of 2017 Corporate FCPA Enforcement Actions

Yesterday’s post [1] compared corporate FCPA enforcement actions in 2017 to prior years. However, before a Foreign Corrupt Practices Act enforcement action is announced, scrutiny must first arise.

Today’s post highlights the origins of 2017 corporate enforcement actions. (See here [2] for a similar post highlighting the origins of 2016 corporate enforcement actions).

As highlighted in the post, like prior years, 2017 corporate enforcement actions originated in a variety of ways from voluntary disclosures, to foreign media reporting and foreign law enforcement investigations, to pro-active SEC investigations, to civil litigation.

Voluntary Disclosure (4)


CDM Smith


SBM Offshore


Foreign Media Reporting / Foreign Law Enforcement Investigations (4)




Keppel Offshore & Marine

Prior FCPA Resolutions (2)

Zimmer Biomet


Pro-Active SEC Inquiries (2)



Civil Litigation (1)

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