Tagged: fcpa enforcement pilot program

Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)

Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)

We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017. From the narrow perspective of FCPA enforcement, the Justice Department and the SEC have demonstrated yet again the maturation of their respective aggressive FCPA enforcement programs. As in 2014 (but not...

The Power of a Justice Department Declination

The Power of a Justice Department Declination

Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination. You can listen to our podcast here. It is always a pleasure to work with Tom and our discussion centered on a number of issues, including DOJ’s FCPA Pilot...

DOJ’s New FCPA Enforcement Plan and Guidance (Part I of II)

DOJ’s New FCPA Enforcement Plan and Guidance (Part I of II)

The Justice Department finally released its long-awaited new FCPA enforcement plan. It took DOJ a little while to come up with this and in the end, like most initiatives, there is a mixed bag for global companies, FCPA practitioners, DOJ prosecutors and law enforcement. Today’s posting analyzes the initiative on prosecution issues, and tomorrow’s post will review the compliance component of the new guidance. DOJ’s...