A most “daring act” seems to be a good way to introduce a multipart look at the recent Foreign Corrupt Practices Act enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a criminal penalty of $15.5 million and a civil penalty of $15 million for a total fine and penalty of $30.5 million. The company settled with the Department of Justice via a Criminal Information and Deferred Prosecution Agreement (DPA) and the Securities and Exchange Commission via a Cease and Desist Order (Order).
