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, 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…

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…

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…

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.…

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…

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…