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Do “many business leaders now appreciate that the FCPA offers them a measure of protection against foreign corruption.”?
This is a direct quote from the State Department’s recently released “National Action Plan on Responsible Business Conduct.” (See here).
There is no citation for this assertion and query what “measure of protection” even means?
The full

A few hours after the DOJ announced a March 28th Foreign Corrupt Practices Act action against Trafigura (see here and here for prior posts) the DOJ also announced (what was increasingly becoming obvious over the last few years) that “its long-running investigation into international commodities trading companies that paid bribes to win business with state-owned

This recent Wall Street Journal article titled “DOJ Uncovering More Misconduct Through Self-Disclosure Program, Says Top Official” begins:
“More companies are choosing to voluntarily disclose misconduct to prosecutors after a policy revision last year that increased the potential benefits of doing so, a top Justice Department official said.

As stated in the article:

“When you see these

Since 2021, the DOJ has resolved 19 corporate Foreign Corrupt Practices Act enforcement actions.
The “Foreign” in Foreign Corrupt Practices Act refers to the location of the bribe recipient (as in “foreign” non-U.S. officials).
However, the “Foreign” in Foreign Corrupt Practices Act might as well refer to the location of the bribe payor as well

Ericsson
As highlighted in this prior post, in 2019 Ericsson (a Swedish telecom company with American Depositary Shares traded in the U.S.) resolved a $1.06 billion FCPA enforcement action concerning conduct in Djibouti, China, Vietnam, Kuwait, Indonesia, and Saudi Arabia.
As part of the resolution, Ericsson was required to engage an independent compliance monitor for

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2024.
DOJ Enforcement (Corporate)
The DOJ announced three corporate enforcement actions in the first quarter. Net FCPA settlement amounts in these enforcement actions totaled $638.2 million.

SAP (Jan 10)
See here and here for prior

First it was Sargeant Marine in 2020 (see here for the prior post).
Then it was Vitol in 2020 (see here for the prior post).
Then it was Glencore in 2022 (see here for the prior post).
Then it was Freepoint Commodities in 2023 (see here for the prior post).
Then it was Gunvor in