There is a common narrative in certain circles that the FCPA was dormant for its first 20-25 years. Five minutes of simple research provides the following examples.
The FCPA was passed in 1977 but “the statute effectively lay dormant
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Individual Pleads Guilty In Connection With Prior FCPA Enforcement Actions Involving Ecuador
By Mike Koehler
This prior post discussed the many FCPA (and related) enforcement actions concerning Ecuador’s Seguros Sucre S.A. (“Seguros Sucre”), an alleged state-owned insurance company and “instrumentality” of the Ecuadorian government.
Among the enforcement actions were criminal charges announced by the DOJ in…
Stericycle DPA Ends
By Mike Koehler
As highlighted in this prior post, in mid-2022 Stericycle (an Illinois based medical waste disposal company) resolved a net $59 million parallel DOJ and SEC enforcement action concerning conduct in Brazil, Mexico, and Argentina.
The DOJ enforcement action involved…
PT Telekomunikasi Indonesia Discloses Scrutiny
By Mike Koehler
PT Telekomunikasi Indonesia, an Indonesia-based telecommunications company with American Depositary Receipts traded in the U.S., recently disclosed in this SEC filing.
“In October 2023, the Company received a document request from the U.S. Securities and Exchange Commission (“SEC”) as…
A Closer Look At Korea Supply Co. v. Lockheed Martin
By Mike Koehler
Since California Attorney General Rob Bonta issued this Legal Advisory titled “Alert to Businesses on Violations of the Foreign Corrupt Practices Act” (see here for the prior post), there has been commentary suggesting that a “new chapter of FCPA enforcement…
U.K. Announces Enforcement Action Involving Insurance Sector In Ecuador
By Mike Koehler
As detailed below, in the past approximate five years, there have been several FCPA enforcement actions against companies and individuals involved in the insurance sector in Ecuador.
Tysers Insurance Brokers Limited and H.W. Wood Limited (2023)
As highlighted in this…
Questions
By Mike Koehler
Dan Seltzer (Managing Director; Senior Director of Anticorruption and Government Compliance at Accenture) recently published this post titled “FCPA Developments.”
This post poses a number of questions to Seltzer in an effort to understand some of his assertions and commentary.…
Rewind – The BAE FCPA Enforcement “Pause”
By Mike Koehler
Fifteen years ago, there was a “pause” in FCPA enforcement.
No, not pursuant to an Executive Order, but as a practical matter.
According to the Department of Justice, BAE served as the “prime contractor to the U.K. government following the conclusion…
Digicel Scrutiny Update
By Mike Koehler
In November 2024, Digicel disclosed Foreign Corrupt Practices Act scrutiny (see here for the prior post).
Specifically, the company stated:
“We voluntarily disclosed to the US Department of Justice information related to possible violations of the US Foreign Corrupt Practices…
DOJ “Intends To Proceed To Trial” In Two Other Pending FCPA Matters
By Mike Koehler
Last week when the DOJ dismissed its long-standing FCPA enforcement action against former Cognizant Executives Gordon Coburn and Steven Schwartz, I told anyone who would listen that it was wrong to view the development exclusively through the lens of the…