FCPA Report Q1 2017

Quarterly Events

During the first quarter of 2017, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved a combined six matters with penalties and disgorgements exceeding $257 million. The cases spanned over five industries, highlighting that no industry is immune to regulatory scrutiny. These cases emphasize that cooperation between international regulators and prosecutors continues to be of importance and that international enforcement authorities are taking a more active role in resolving enforcement actions.

In addition to prosecuting these cases, the DOJ announced that the Foreign Corrupt Practices Act (“FCPA”) Pilot Program, set to take place for one year, would continue. Guidance for the FCPA, entitled “Evaluation of Corporate Compliance Programs,” was issued and provides guidance on topics and questions that the DOJ’s Fraud Section has frequently found relevant in evaluating a corporate compliance program. While these actions perhaps signal that FCPA enforcement will continue to be a high priority with the new administration, and with new leadership at both the DOJ and the SEC, it will be interesting to watch whether the number of enforcement actions trends upward or downward as the year progresses.


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