Foreign Corrupt Practices Act enforcement officials always like to remind the public that the “pipeline” (that is DOJ or SEC matters under investigation) is full.
After all, the mere mention of a full pipeline – or the more sophisticated term – a “robust” pipeline may achieve some level of general deterrence and serve as a reminder to the public that prosecutors are still going to work and doing their job.
So it was earlier this week when Nicholas McQuaid (the DOJ’s Principal Deputy of the DOJ’s Criminal Division) spoke at an FCPA “dog and pony” show (that is an American Conference Institute event) and stated:
“I wouldn’t over read or really read much into the numbers of prosecutions in a given year.
“We have what we view as a very robust pipeline. I would expect to see some significant resolutions in the next year.”
As reported here:
Mr. McQuaid … said those keeping score should expect to see some new types of cases in the near future. He said prosecutors were diversifying their caseloads by coming up with new investigative techniques and forging relationships with more foreign counterparts. Cases involving FCPA violations now regularly involve bringing coordinated charges with authorities in multiple countries.
“I would expect to see some resolutions from places that are familiar to folks, and also some new ones that people haven’t seen in the past.”
The Justice Department has increasingly pressured companies to develop more sophisticated compliance systems, including through the use of data and analytics tools. Prosecutors also are using data to find new FCPA cases, Mr. McQuaid said.
“We’re continuing to find ways to use data from across the government to help us identify places to focus [our] energy. “That certainly includes use of those techniques in the FCPA space.”
“You’re going to see resolutions and individual prosecutions that reflect that hard work.”
Up north in Canada, the pipeline is also apparently full.
As reported here:
“RCMP anti-corruption investigators say they are probing possible shady practices by several Canadian companies operating in parts of Africa, Eastern Europe and South America. Firms involved in mining, infrastructure, aviation, rail, engineering and technology are susceptible to corruption, such as paying a bribe to secure a contract, say Mounties with the force’s sensitive and international investigations section.”
