For those who might have wondered if the Jeff Sessionsโ Justice Department was going to enforce the Foreign Corrupt Practices Act (FCPA), that question seems to have been answered in the affirmative. In September, the DoJ and Securities and Exchange Commission announced the largest FCPA fine ever, that being against Telia Company at $965MM. Now we have five criminal matters involving individuals who all were involved in the Rolls Royce corruption case, in which the corporate matter had been resolved in January before the new administration took power.



