Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

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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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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