The second quarter of 2017 was relatively quiet from an enforcement perspective. Two Magyar Telekom executives settled cases that the Securities and Exchange Commission (“SEC”) had filed against them, and two entities received declination letters from the Department of Justice (“DOJ”).
In addition to the above-mentioned cases, statements by DOJ officials indicated that enforcement of the Foreign Corrupt Practices Act (“FCPA”) and cooperation with international regulators and prosecutor continue to be important priorities, despite a change in administration and leadership at the DOJ. DOJ officials also noted the importance of the FCPA Pilot Program in its efforts to root out instances of corporate bribery and corruption. Finally, in Kokesh v. SEC the U.S. Supreme Court held that disgorgement is subject to a five-year statute of limitations – which has potential to impact how long SEC FCPA investigations take.