The Department of Justice and Securities and Exchange Commission have continued a stunning 2016 run of Foreign Corrupt Practices Act decisions with the announcement of the resolution of the Embraer SA (Embraer) FCPA enforcement action.
The resolution documents included a Deferred Prosecution Agreement (DPA) and Criminal Information (Information) with the DOJ and a Complaint with the SEC.
This paper from Thomas Fox is the first in a multi-part series exploring the enforcement action, considering the government’s case and the company’s response and, finally, the lessons to be learned by the compliance practitioner.
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