The Department of Justice and the Securities and Exchange Commission have settled a raft of Foreign Corrupt Practices Act cases in recent months, including agreements with Alcoa, Archer Daniels Midland, Diebold, and Weatherford International. The cases point to some important trends in FCPA enforcement: expanded cross-border cooperation and prosecutions, the emergence of the hybrid corporate monitor, and an upsurge in FCPA fines and penalties.
Taken together, the multitude of recent FCPA enforcement actions speaks volumes about how companies can avoid or minimize liability under the FCPA and reflect the latest thinking of regulators as they pursue these cases. Compliance and legal executives can also use these real-life cases in their compliance and ethics training to deter bribery and corruption practices in the workforce.
