FCPA enforcement


FCPA Enforcement: Corporate Crime and Punishment

It appears that due to a steady increase in cooperation requirements and a projected decrease in voluntary disclosures, the DOJ may be re-examining its incentives for corporations that self-report. While corporate penalties are integral in driving governance reform, so too are individual prosecutions. The challenge the DOJ is faced with at this point is striking a balance between ...


Highway 61 and IRS Involvement in FCPA Enforcement

If you need a reason to bolster your monitoring efforts, you may find the recent FCPA enforcement action against Vicente Eduardo Garcia to be quite instructive. One noteworthy feature of this investigation was the involvement of the IRS’s Criminal Investigation unit, the lesser-discussed of the DOJ’s two investigative bodies, called in to comb through mountains of data and ...

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A Boost in FCPA Declinations? Why FCPA Enforcement Has Fallen This Year

The number of FCPA declinations is on the rise, while the number of enforcement actions is at its lowest level in more than a decade. Now, this doesn't mean companies and individuals suspected of corruption are getting away with anything; instead, the drop in enforcement actions could have everything to do with the fact that the subjects of ...

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Berger FCPA Settlement: Back to the Future

Louis Berger International has agreed to pay $17 million and retain a compliance monitor for three years to settle bribery charges. At the same time, the Department of Justice handed down judgment on two Berger executives. The case, which was settled a few weeks ago, raises questions about the DOJ's handling of similar cases -- specifically regarding ...

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The Sigelman Case and the DOJ’s FCPA Trial Record

Some are foaming at the mouth about the outcome of the FCPA trial of former PetroTiger CEO Joseph Sigelman. However, while the Department of Justice isn't overjoyed with how the case turned out, the outcome isn't at all unusual. The key takeaway here: you win some, you lose some. Will the DOJ overhaul it's FCPA enforcement ...

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The FIFA Indictments and Travel Act Prosecutions under the FCPA

Last week, 14 officials and individuals associated with FIFA were indicted on corruption, racketeering, and conspiracy charges. And while the defendants haven't exactly violated the FCPA, U.S. authorities are bringing charges under the Travel Act, which prohibits the use of the mail or any facility in interstate commerce to engage in illegal activity.


Top FCPA Enforcement Trends To Expect in 2015

The future is often a mystery, but here and there we're given insight into what's coming. FCPA authorities have done just that for us over the past few months, speaking often about their intentions for investigations and enforcement actions ahead. So instead of just guessing at what the landscape will look like this year, we can just ...


What FCPA Enforcement was Thinking in 2014

FCPA enforcement agencies don't tend to keep their intentions secret. If you follow the investigations and enforcement actions, it's easy to discern where their focus lies and how companies can "buy" themselves some leniency. Officials at the DOJ and SEC have offered several insights into the agencies' thought processes for 2014. What do you think 2015 ...

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Is the Paper Tiger Sharpening its Teeth?

In terms of FCPA enforcement, the UK's Serious Fraud Office doesn't hold a candle to the U.S. Department of Justice. Not yet, anyway. Over the past few months, it has become clear that the tide is turning; the SFO has several high-profile cases in the works and is seeking to extend its reach with an expanded arsenal ...


FCPA Mid-Year Assessments

Despite what the various FCPA mid-year assessments are saying, FCPA enforcement is not on the wane. It's here to stay, and if anything, efforts are likely to increase rather than subside. Although the SEC has come under scrutiny for its unnecessarily lengthy investigations, essentially delaying justice, there are and will continue to be significant prosecutions forthcoming.