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The Origins Of 2018 Corporate FCPA Enforcement Actions

Yesterday’s post [1] compared corporate FCPA enforcement actions in 2018 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 2018 corporate enforcement actions. (See here [2] for a similar post highlighting the origins of 2017 corporate enforcement actions and here [3] for 2016 corporate enforcement actions).

As highlighted in the post, like prior years, 2018 corporate enforcement actions originated in a variety of ways from voluntary disclosures, to pro-active government investigations and industry sweeps, to foreign law enforcement investigations.

Voluntary Disclosure (7)

Pro-Active Government Investigation / Subpoena (4)


Foreign (Brazil) Law Enforcement Investigation (3)

Industry Sweep (1)

Unclear (1)

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