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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