Fact.
The DOJ has long closed FCPA inquiries without bringing any actual enforcement action (regardless of form).
Observation.
It seems like in the past few months when a company has disclosed this rather routine DOJ practice, some are responding with outrage.
Yet, where was the outrage when the DOJ under prior administrations closed FCPA inquiries?
Is not selective outrage a rather obvious sign of so many things?
For example, below is a sample list of FCPA inquiries closed by the DOJ (without bringing any actual enforcement action – regardless of form) during the Biden administration.
- Stanley Black & Decker
- Arthur G. Gallagher
- Cisco
- Baker Hughes
- Pactiv Evergreen
- Avianca Holdings
- BRF
- Leidos
