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Painful Lessons Learned From Alstom, Avon Settlements

Tom Fox | January 13, 2015

Not since November, 2010, when the Justice Department announced its many settlements with Panalpina on Foreign Corrupt Practices Act charges, have we seen such a stunning back-to-back announcement of resolution of long-running and highly public FCPA enforcement actions.

I am, of course, referring to the Avon and Alstom FCPA enforcement actions announced in December. Alstom engaged in multi-country bribery schemes over several years, sometimes in the open and sometimes (seemingly) trying to hide the details of the bribery to the corporate headquarters in France. Avon engaged in a systematic bribery scheme in one country (China) followed by a...

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