FCPA Enforcement On Near-Record Pace For 2016: Part 2

By John Davis, Marc Alain Bohn and Michael Skopets, Miller & Chevalier Chtd. (November 14, 2016, 4:16 PM EST) -- John E. Davis

Marc Alain Bohn

Michael Skopets Over at least the last decade, the U.S. Securities and Exchange Commission and the U.S. Department of Justice have, on balance, resolved comparable numbers of corporate enforcement investigations under the Foreign Corrupt Practices Act each year. Since 2015, however, this balance has shifted, with the SEC entering into more than twice as many corporate dispositions as the DOJ during the same time frame, when counting each agency's distinct actions against affiliated corporate entities as a single, "combined" resolution. As opposed to a reduced focus on enforcement by the DOJ or an uptick in...

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