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This Week On FCPA Professor


FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

This post highlights what you need to know from Q4.

All month FCPA Professor will be the place to visit for 2021 FCPA year in review statistics.

To start things off, this post compares 2021 corporate FCPA enforcement to prior years.

Before an FCPA enforcement action is announced, scrutiny must first arise and this post highlights the origins of 2021 corporate enforcement actions.

As highlighted here, like prior years, the gray cloud of FCPA scrutiny simply lasts too long. Specifically, 4 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2021 were under scrutiny.

This post goes in-depth into various facts and figures relevant to SEC FCPA enforcement in 2021.

This post focuses on SEC individual actions. SEC rhetoric about individual accountability aside, the SEC did not bring an FCPA enforcement action against any individual in 2021 and the current time gap between individual SEC FCPA enforcement actions has been approximately 15 months – the longest in nearly a decade.

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