This week, the SEC and Justice Dept. resolved another FCPA enforcement action, this one involving Johnson Controls, Inc. (JCI). This case continues the path set up by the new Justice Dept. Pilot Program and three subsequent FCPA enforcement actions, Akamai Technologies, Inc. and Nortek, Inc. and Analogic Corp.; where the Justice Dept. issued a Declinations to Prosecute the first two companies and the third received a non-prosecution agreement. Clearly, the Justice Dept. is communicating that companies will see significant benefits if they follow the precepts set out in the Pilot Program.
