4 Lessons From Total's FCPA Settlement

Law360, New York (June 5, 2013, 12:49 PM EDT) -- On May 29, the U.S. Securities and Exchange Commission and the U.S. Department of Justice announced that France-based oil and gas company Total SA resolved Foreign Corrupt Practices Act charges by agreeing to pay a near record-setting $398.2 million. In addition to the magnitude of Total's payout, the case is notable for other reasons, too — the vintage of the misconduct and investigations; the appointment of an independent compliance monitor; the continued expansion of international enforcement cooperation in FCPA matters; and the number of classic FCPA risk factors involving third parties present in the charged conduct....

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