In July 2009, FCPA Professor was launched with this simple mission statement.
Sixteen years and approximately 4,700 posts later, FCPA Professor is still here and the mission remains the same. In fact, FCPA Professor is the longest running daily information
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Where Was The Outrage?
By Mike Koehler
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…
Insight On The Pintado Matter
By Mike Koehler
This post is from Andrew Feldman (Feldman Firm PLLC).
Since President Trump issued the Executive Orders “pausing” the enforcement of the FCPA, lots of large law firms decried the potential end of the FCPA and worried that there would be…
The General Lack Of FCPA Judicial Decisions
By Mike Koehler
Many Foreign Corrupt Practices Act defendants and their counsel who actively litigate against the DOJ ultimately run into the same issue.
The DOJ’s argument in briefing that there are no FCPA cases on the disputed issue or that other cases…
The FCPA And Snyder
By Mike Koehler
Mid-Year FCPA Enforcement Compared to Prior Years
By Mike Koehler
Much of the media coverage surrounding the 118 day FCPA enforcement “pause” lacked context including as to what “normal” FCPA enforcement looks like.
This post provides that context.
The below chart highlights mid-year FCPA enforcement (Q1 and Q2) over the…
FCPA Defendant Moves To Dismiss Indictment
By Mike Koehler
In late 2023, the DOJ announced the unsealing of an indictment criminally charging: Carl Alan Zaglin (the owner of a Georgia-based manufacturer of law enforcement uniforms and accessories); Francisco Roberto Cosenza Centeno (former Executive Director of the Comité Técnico del Fideicomiso para…
The Least Expensive FCPA Corporate Settlement Amounts
By Mike Koehler
In response to this list earlier this week highlighting the current top ten list of FCPA settlement amounts, a reader asks: what about the “least expensive” FCPA settlements?
Such a list would include many, many entries for $0 settlement amounts.…
ABB DPA Ends
By Mike Koehler
The first time ABB resolved a Foreign Corrupt Practices Act enforcement action was in 2004 concerning conduct in Nigeria, Angola and Kazakhstan.
The second time ABB resolved an FCPA enforcement action was in 2010 concerning conduct in Mexico as well as…
Top Ten FCPA Settlement Amounts
By Mike Koehler
With the Foreign Corrupt Practices Act enforcement “pause” over (at least as a formal matter), here is where things stand in terms of the current top ten corporate FCPA settlements of all-time actually secured by U.S. law enforcement (in other words…