In this issue:
- Recent Trends and Patterns in FCPA Enforcement
- Recent Trends and Patterns in FCPA Enforcement Enforcement
- Actions and Strategies
- Statistics
- Types of Settlements
- Elements of Settlements
- Case Developments
- Perennial Statutory Issues
- Instrumentality
- Parent/Subsidiary Liability
- Jurisdiction
- Anything of Value
- Compliance Guidance
- Gifts and Entertainment
- Specific Compliance Failures
- Unusual Developments
- Prosecution of Foreign Officials
- Sealed Indictments
- Whistleblower Confidentiality Statements
- Multi-Jurisdictional Investigations and Prosecutions
- Enforcement in the United Kingdom
- Deferred Prosecution Agreements
- U.K. Modified Sentencing Guidelines
- SFO Investigations
- Conclusion Thus far, although the number of enforcement actions has been lower than we’ve seen in prior years, 2014 has seen a trio of significant corporate prosecutions and several new individual cases. Among the highlights from 2014 are:
- Average corporate fines and penalties of $193.3 million, significantly above the average of previous years due to three enforcement actions including large sanctions;
- The DOJ’s use of plea agreements and the SEC’s use of administrative proceedings has increased over the use of deferred prosecution and non-prosecution agreements;
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