DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II)
The Justice Department’s FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred. DOJ’s record is hard to square against DOJ official speeches, statements and policy changes, which all were premised on an expectation of increased enforcement over prior years. In its last FCPA enforcement...