Reflections On 2017 FCPA Enforcement

Law360 (February 7, 2018, 12:19 PM EST) -- Despite significant Foreign Corrupt Practices Act enforcement activity in 2017, the Trump administration’s approach to enforcement remains elusive and not readily characterized.

Looking at 2017 as a whole, the number of corporate enforcement actions resolved by the U.S. Department of Justice and the U.S. Securities and Exchange Commission was within the range of fluctuations in such numbers in recent years, though down from 2016’s record-breaking total. Looking at the year more closely, we find that eight of the 14 corporate resolutions by the DOJ and the...
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