Gartner Settles FCPA Case with SEC for $2.5 Million
The SEC has been racking up several FCPA enforcement actions. DOJ appears to be declining many of these cases. The division of enforcement appeared to follow a pattern – on larger cases with more pervasive violations, DOJ and the SEC would each bring an enforcement action; while on relatively “smaller” cases, the SEC would bring a case and the DOJ would decline to prosecute. This...