Painful Lessons Learned From Alstom, Avon Settlements

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...