Recent Trends And Patterns In FCPA Enforcement -
Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions resulted in penalties over $100 million. In the past, we have repeatedly noted that although the large FCPA enforcement actions grab the headlines, the bulk of enforcement actions are actually relatively small (often under $30 million in penalties). The first half of 2019 has been an exception, resulting in some of the highest penalty statistics of any half year of FCPA enforcement.
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