During the recently completed third quarter of 2017, the Department of Justice (DOJ) resolved one matter and the Securities and Exchange Commission (SEC) resolved two matters. While this was a slow quarter in terms of the number of enforcement actions, the financial impact was significant as the Telia global settlement involved financial penalties and disgorgement of approximately $965 million to be allocated between U.S., Dutch, and Swedish authorities. Public statements from both the DOJ and the SEC seem to indicate that enforcement of the Foreign Corrupt Practices Act (FCPA) remains a high priority for both, so no conclusions should be drawn from the minimal enforcement activity this quarter. In fact, some sources note that more than 125 companies are either under investigation by the DOJ/SEC or are conducting their own internal investigations.
Special thanks to Andrew Lind, who contributed to this report.