Nordion: A Contrast in FCPA Enforcement Actions
FCPA enforcement actions run the gamut of fact patterns and structured resolutions. We are in the midst of a transformation in the overall settlement environment with an expected increase in individual prosecutions. On the one side, we have a tough and comprehensive DOJ and SEC settlement against VimpelCom. The conduct within VimpelCom was pervasive and occurred at every level of the company, including the board....