The previous Foreign Corrupt Practices Act record in terms of settlement amounts was 2016 in which the DOJ and SEC collected approximately $2.4 billion (see here). With last week’s record-setting $1.06 billion enforcement action against Ericsson (see here), 2019 has eclipsed 2016. With approximately three weeks left in 2019 (keep in mind the end of the calendar year has historically been an active period for FCPA enforcement), the DOJ and SEC have collected…
Everybody, it seems, likes “Top Ten” lists. This post highlights the top ten corporate FCPA settlements of all-time. It seems odd saying this, but the list (unlike other lists) only includes enforcement actions where the corporate defendant was charged with or found to be in violation of the FCPA’s provisions (not other laws). In addition, the list highlights net FCPA settlement amounts actually secured by U.S. law enforcement after consistently accounting for (unlike other lists
Late last Friday, the DOJ and SEC announced (here and here) a record-setting Foreign Corrupt Practices Act action Swedish telecom company Ericsson (a company with American Depositary Shares traded in the U.S.). The $1.06 billion settlement amount is the largest net FCPA settlement amount in history surpassing the $850 million FCPA enforcement action against Russian telecom company MTS in March 2019 (see here). The enforcement action concerned conduct in Djibouti, China, Vietnam,…
FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.” Set forth below are the topics discussed this week on FCPA Professor. As highlighted here, the Bribery Risk Matrix recently released by Trace International restates the obvious. This post highlights issues to consider from the recent Samsung Heavy Industries enforcement action. Forced to brief the issue,…
Earlier this week, Assistant Attorney General Brian Benczkowski delivered this speech at the FCPA’s annual dog and pony show (also know as the American Conference Institute’s FCPA conference). As highlighted below, in the speech Benczkowski discussed individual and corporate enforcement, the DOJ’s Kleptocracy Asset Recovery Initiative, the recent trial in the Hoskins matters and agency issues, as well as DOJ policy. Benczkowski began by noting the “remarkable prosecution activity and case developments in the FCPA space…