A post on the FCPA Blog on 7 October asked this question, the poster saying that he had analysed 7 consecutive corporate FCPA enforcement actions from 2020 and found that all involved non-compliant behaviour that started at least 8 years ago.  In 2 cases, the conduct started 10 years ago, in 2 others it started a dozen years ago, and one case involved illegal conduct that started 14 years ago.  He outlines some reasons why there’s so much ancient history in FCPA cases.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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