In an article published by Global Trade, Bass, Berry & Sims attorneys John Kelly and Wally Dietz provided insight on FCPA enforcement trends. The article, referencing the firm’s “FCPA: 2016 Year in Review & 2017 Enforcement Predictions” report, predicts ongoing robust prosecutions, continued cooperation with foreign counterparts in anti-corruption investigations and an extension to a program encouraging self-disclosures.
“Enforcement under the FCPA has never been more aggressive or coordinated in terms of settlement amounts and number of enforcement actions,” said Wally in the article. “It is no longer uncommon for companies to pay in excess of $100 million in civil and criminal penalties to resolve FCPA actions. With that being said, this review aims at providing corporate leaders and companies with the knowledge they need to comply with the FCPA and avoid litigation in 2017.”
According to John’s statements in the article, “in light of the number of settlements deriving from voluntary self-disclosures last year, and the DOJ’s apparent interest in providing mitigation credit to cooperating companies, we anticipate the Pilot Program to be extended – perhaps with little change – throughout this year and potentially coming years.”
The full article, “Report Predicts Ongoing Anti-corruption Enforcement,” was published by Global Trade on April 14, 2017, and is available online.