September is a great month. The heat and humidity of July and August have largely subsided, evenings are crisp and cool, the leaves begin to change, the kids go back to school, college football returns to campus, and oh those honeycrisp apples!
As highlighted in this post, historically September has tended to be an active month for FCPA enforcement. In fact, of the 130 corporate FCPA enforcement actions since 2015, 25 of the actions (approximately 20% have occurred in September).
Why?
Well, the SEC’s fiscal year ends on September 30th and while we would like to think that the government does not “close its books” like a business organization at the end of a fiscal year, this most certainly appears to be the case.
Indeed SEC Commissioner Hester Peirce has called this September dynamic (which is observable not just in FCPA enforcement actions but other actions as well) as the SEC’s “own version of earnings management.” (See here).
Set forth below is a list of FCPA enforcement actions in September since 2015.
September 2024
In September 2024, there were FCPA enforcement actions against the following companies.
Deere & Co. (Sept. 10th) (SEC)
See here for the prior post.
September 2023
In September 2023, there were FCPA enforcement actions against the following companies.
Albemarle (Sept. 29th) (DOJ/SEC)
See here for the prior post.
Clear Channel Outdoors (Sept. 28th) (SEC)
See here for the prior post.
September 2022
In September 2022, there were FCPA enforcement actions against the following companies.
Oracle (Sept. 27th) (SEC)
See here for the prior post.
GOL (Sept. 15th) (DOJ)(SEC)
See here for the prior post.
September 2021
In September 2021, there were FCPA enforcement actions against the following companies.
WPP (Sept. 24th) (SEC)
See here for the prior post.
September 2020
In September 2020, there were FCPA enforcement actions against the following companies.
Sargeant Marine (Sept. 22nd)(DOJ)
See here for the prior post.
September 2019
In September 2019, there were FCPA enforcement actions against the following companies.
Barclays (Sept. 27th) (SEC)
See here for the prior post.
Westport Fuel Systems (Sept. 27th) (SEC)
See here for the prior post.
Quad Graphics (Sept. 26th) (SEC)
See here for the prior post.
TechnipFMC (Sept. 19) (SEC)
See here for the prior post.
September 2018
In September 2018, there were FCPA enforcement actions against the following companies.
Stryker (Sept. 28th) (SEC)
See here for the prior post.
Petrobras (Sept. 27th) (DOJ)(SEC)
See here for the prior post.
United Technologies (Sept. 19th) (SEC)
See here for the prior post.
Sanofi (Sept. 4th) (SEC)
See here for the prior post.
September 2017
In September 2017, there were FCPA enforcement actions against the following companies.
Alere (Sept. 28th) (SEC)
See here for the prior post.
Telia (Sept. 21st) (DOJ)(SEC)
See here for the prior post.
September 2016
In September 2016, there were FCPA enforcement actions against the following companies.
GlaxoSmithKline (Sept. 30th)(SEC)
See here for the prior post
Och-Ziff (Sept. 29th)(DOJ & SEC)
HMT LLC (Sept. 29)(DOJ)
See here for the prior post.
NCH Corp. (Sept. 29)(DOJ)
See here for the prior post.
AB InBev (Sept. 28th)(SEC)
See here for the prior post.
Nu Skin (Sept. 20th)(SEC)
September 2015
In September 2015, there were FCPA enforcement action against the following companies.
Hyperdynamics (Sept. 29th)(SEC)
See here for the prior post
Hitachi (Sept. 28th)
Whatever happens this September, you can be sure that FCPA Professor will provide the most comprehensive and candid real-time coverage publicly available.
