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.
https://fcpablog.com/2021/10/07/why-is-ancient-history-part-of-so-many-fcpa-cases/
raytodd.blog 