Some compliance commentators continue to complain about the dearth of information coming out of the Justice Department about enforcement of the Foreign Corrupt Practices Act.
It hasn’t been completely silent, however. The recent declination provided to Layne Christensen Co., for example, continues what I believe to be a trend of significant communications to the compliance community as to what a company needs to do if it finds itself in FCPA hot water. Moreover, while the company agreed to a Securities and Exchange Commission cease and desist order, which required payments of fines, penalties, and disgorgement of a little over $5 million, the more important sum is what the company did not pay.
