Matteson Ellis Discusses Slowdown in FCPA Enforcement Actions in Corporate Compliance Insights  

"A Boost in FCPA Declinations? Why FCPA Enforcement Has Fallen This Year"
Corporate Compliance Insights
08.12.15In this blog post, Matteson Ellis discusses Miller & Chevalier's FCPA Summer Review 2015. "This year, FCPA enforcement authorities have brought only eight resolved enforcement actions, the lowest mid-year total in a decade. Why the slowdown? Does it represent a fundamental shift in FCPA enforcement?" Ellis said, noting that the Review suggests the answer is no and citing an increase in the number of known declinations. According to the Review, companies should be aware that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) are rewarding voluntary disclosure and cooperation: "The DOJ's frequent inclusion of a rationale in the private correspondence it sends to companies informing them of its declination decisions appears to be part of a coordinated effort by the agency to highlight the benefits of self-reporting and cooperation in the face of possible FCPA violations."
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